Spreadsheet: 0107ac74-a1b5-4bb6-a6bf-9a5d83aa3560
Sheet: Sheet1

* Please provide the name of the entity or individual responding to this request: | 1. * Please describe the entity or individual responding to this request.   For example:                   a. Please indicate whether you primarily are a preparer, user, or auditor of financial statements, or if other, please specify. | Other, please specify | 1. b. As a preparer of financial statements, please indicate whether your entity is public or nonpublic and describe your primary business and its size (in terms of annual revenue, the number of employees, or other relevant metric) in the "Additional Comments" box below. | Additional Comments | 2. As a preparer, do you believe that the proposed amendments will reduce overall costs and complexity compared with existing guidance? If not, please explain why in the "Additional Comments" box below. | Additional Comments.1 | 3. As a preparer, do you expect your entity will choose to perform the qualitative assessment proposed in the amendments, or will your entity choose to proceed directly to performing the first step of the two-step impairment test? Please explain in the "Additional Comments" box below. | Additional Comments.2 | 1. c. As an auditor, please indicate whether your practice focuses primarily on public entities, nonpublic entities, or both and describe the size of your firm (in terms of number of partners, or other relevant metric) in the “Additional Comments” box below. | Additional Comments.3 | 4. As an auditor, do you believe that the proposed amendments will reduce overall costs and complexity compared with existing guidance? If not, please explain why in the "Additional Comments" box below. Please explain why if your response differs based on whether the entity is public or nonpublic? | Additional Comments.4 | 1. d. As a user of financial statements, please indicate in what capacity (for example, investor, analyst, or rating agency) and where in the capital structure you are most focused (for example, debt or equity). | 5. As a user of financial statements, do you believe that the qualitative approach for testing goodwill for impairment will delay the recognition of goodwill impairment losses or affect how you evaluate goodwill reported in the financial statements? If yes, please explain why in the "Additional Comments" box below. | Additional Comments.5 | 6. Do you agree that the proposed examples of events and circumstances to be assessed are adequate? If not, what changes do you suggest? (Enter in "Additional Comments" box below.) | Additional Comments.6 | 7. Do you agree that the guidance in the proposed amendments about how an entity should assess relevant events or circumstances is clear? If not, how can the guidance be improved? (Enter in "Additional Comments" box below.) | Additional Comments.7 | 8. Do you agree with the Board’s decision to make the proposed amendments applicable to both public entities and nonpublic entities? If not, please explain why in the "Additional Comments" box below. | Additional Comments.8 | 9. Do you agree with the proposed effective date provisions? If not, please explain why in the "Additional Comments" box below. | Additional Comments.9 | 10. If you wish to provide any additional comments or observations about the proposed amendments please do so below: | Completed
[NAME], cpa/abv, mba | Auditor |  |  |  |  |  |  |  | Nonpublic entities |  | Yes | Private company reporting is generally done for the benefit of a lender.  Lenders, in underwriting a new loan and reviewing an existing loan, look at the Company's tangible book value (excludes intangible assets such as goodwill) and its cash flow (excluding non-cash items such as amortization). As a result, I think little (if any) weight is lent to the value of the intangible assets.  Therefore, my first suggestion would be to go back to amortization of all intangibles.  But at a minimum, it would make sense to NOT spend a ton of money on valuation analysis annually.  I think the proposed guidance is a great first step. |  |  |  | Yes |  | Yes |  | No | In the public realm, value is measured daily by the market.  Therefore, the first step of the process is done for you.  If public companies are able to make a qualitative analysis that supports that a valuation is not required, even though the valuation is already performed by the stock market and supports the fact that the market value is less than the book value, this would be a detriment to investors. There are a handful of financial companies whose market capitalization is less than their tangible book value and yet they have a substantial amount of intangible assets on their books that have been there for many years with no write down taken.  I can't see how this can be ignored based upon qualitative factors. | Yes |  |  | 2011-04-25 10:40:57.604000
[NAME] | Auditor |  |  |  |  |  |  |  | Nonpublic entities |  | Yes |  |  |  |  | Yes |  | Yes |  | No | Proposed amendment should only be applicable to nonpublic entities. | Yes |  |  | 2011-04-26 08:20:39.762000
[NAME] | User |  |  |  |  |  |  |  |  |  |  |  | Financial statements are used in our capacity of advisors related to business relationships.  I perform financial reviews of potential partners, and determine whether the relationship should be persued, or whether the financial strength is insufficient to warrant a relationship. | No | Generally, "[NAME]" is a worthless asset, and the company generally is well aware that it is an accounting creation. | Yes |  | Yes | You will be unable to idiot proof any guidance. | Yes |  | Yes |  | When using financial statements, one of the first adjustments I make before computing any ratios, or other analysis is to eliminate [NAME], and identifiable other intangibles fromt the assets and equity.  [NAME] is an accounting convention, and just as negative goodwill is now recognized as a bargain purchase gain in GAAP now, rather than allocated to reduce fair value as it was in the past, positive [NAME] should be recognized as a speculative loss immediately, the price paid exceeds net fair values as a result of expectations that are beyond the reasonable expectations used in deriving the fair values, and should be recognized as a loss immediately. | 2011-04-26 11:41:19.285000
[NAME] | Auditor |  |  |  |  |  |  |  | Nonpublic entities |  | Yes |  |  |  |  | Yes |  | Yes |  | Yes |  | No | Would prefer for fiscal years beginning after 12/15/10. | As a small town CPA, I support this amendment. | 2011-05-10 11:28:36.919000
[NAME] | Auditor |  |  |  |  |  |  |  | Nonpublic entities |  | Yes | It is a logical and common sense approach that will eliminate clients going through the motions to meet accounting standards when it was simply unnecessary. |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-05-10 13:06:45.610000
[NAME] | Preparer |  | Public |  | Yes |  | Utilize qualitative assessment |  |  |  |  |  |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-05-12 02:38:13.499000
Everbank | Preparer |  | Nonpublic |  | No | Not sure. | Utilize qualitative assessment |  |  |  |  |  |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-05-12 09:37:21.606000
[NAME] | Other, please specify | taking a college course |  |  |  |  |  |  |  |  |  |  |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-05-13 08:18:14.553000
[NAME], President, Corporate Value Partners, Inc. | User |  |  |  |  |  |  |  |  |  |  |  | I am a business valuation analyst, and am focused on the entire capital structure. | No |  | Yes |  | Yes |  | Yes |  | Yes |  | Thank you for the opportunity to comment on the Goodwill Impairment Testing Exposure Draft. I believe that the proposed amendments will improve financial accounting.  In analyzing a management team’s performance, it is very useful to see where they’ve spent money in the business. Are they managing accounts receivable and inventory well? Are they over-spending on machinery and equipment? Are they acquisition happy and paying big premiums? The only way we know this is if the balance sheet captures management’s activities. With respect to goodwill impairment, our predisposition should be to retain goodwill on the balance sheet. Only then can we better analyze management’s performance and their ability to generate an adequate return on the acquisitions they’ve made. In fact, the relative amount of goodwill on a balance sheet is an important marker indicating management’s strategy and capabilities in light of their profitability. Additionally, goodwill impairment testing can prod poor management teams into “big bath” accounting – “Well, it’s a bad year anyway, so let’s take the hit on goodwill too. Maybe investors will be less likely to notice our sub-par acquisition record.”   We are making a giant mistake if we believe that financial statements should reflect the current value of a firm; in essence reflecting the stock market’s opinions. Financial statements are a record of management’s investments and their ability to generate a return on those investments. It is up to the stock market, not management teams and accountants, to determine the relative value that management teams have added to the investments they’ve made with investors’ and lenders’ money.  Thank you again for the opportunity to offer my comments.  Sincerely,  [NAME] President Corporate Value Partners, Inc. 1340 Depot Street, [NAME] 102 Rocky River, Ohio 44116 [PHONE] [PHONE] FAX [EMAIL] www.DealDesk.com | 2011-05-13 09:41:53.167000
Carnival Corporation & plc | Preparer |  | Public | Carnival Corporation & plc is the largest cruise vacation group in the world, with a portfolio of cruise brands in North America, Europe, Australia and Asia, comprised of Carnival Cruise Lines, Holland America Line, Princess Cruises, Seabourn, AIDA Cruises, Costa Cruises, Cunard, [NAME], P&O Cruises (UK) and P&O Cruises (Australia).  Traded on both the New York and London Stock Exchanges, Carnival Corporation & plc is the only group in the world to be included in both the S&P 500 and the FTSE 100 indices. | Yes |  | Utilize qualitative assessment |  |  |  |  |  |  |  |  |  | We believe that the examples of events and circumstances as discussed in the proposed guidance are adequate to guide the preparer in making a professional judgment as to whether it is more likely than not that its goodwill has been impaired. It is understood that this list is not exhaustive and other applicable circumstances should be considered as applicable to the specific entity. | Yes |  | Yes |  | Yes |  |  | 2011-05-18 18:20:42.035000
[NAME] | Preparer |  | Nonpublic | Alternative Health Products, primarily vitamins and nutritional supplements, 150 employees, $175 million annual revenue. | Yes |  | Utilize qualitative assessment |  |  |  |  |  |  |  |  | No | Add one additional qualitative review of previous valuations.  An additional item to consider is the degree of room between previous valuations and the NBV of the company or the unamortized cost of the intangibles. | Yes |  | Yes |  | Yes |  | This will save us as a small company considerable time during a period of the year when we are very busy meeting audit and tax deadlines. | 2011-05-23 12:03:04.968000
Debbie Juretus | Preparer |  | Nonpublic |  | Yes |  | Utilize qualitative assessment |  |  |  |  |  |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-05-23 15:52:38.683000
RubinBrown LLP | Auditor |  |  |  |  |  |  |  | Both |  | Yes | We believe that the costs to the issuing entity will generally be reduced as the qualitative anaysis will require less time than complying with Step 1 under existing guidance. However, audit costs could be increased in situations where the entity and the auditor are not in agreement regarding the qualitative analysis. In situations where fair values are available, the option to forego the qualitative analysis will help assure that costs will not be higher by having to do the analysis. |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-05-28 00:11:12.183000
SunTrust Banks, Inc. | Preparer |  | Public | SunTrust Banks, Inc. is one of the nation’s largest banking organizations with assets of approximately $171 billion as of March 31, 2011 of which $6.3 billion relates to goodwill. | No | While it appears that the proposed amendment has the potential to reduce overall costs, we would still incur significant time and resources to research and document our conclusion since the assessment is a highly subjective and complex process.  In addition, our external auditors could disagree with our qualitative assessment results or the results could be inconclusive, and the step 1 impairment test would need to be performed.  Many of the proposed qualitative factors are already considered for current goodwill impairment testing.  Therefore, we do not believe that our overall costs will be significantly reduced as a result of the ED. | Perform first step of the test | We may utilize the qualitative assessment for some reporting units; however, we will likely continue to perform the first step of the test for purposes of annual goodwill impairment testing for the majority of our reporting units. |  |  |  |  |  |  |  | No | The proposed examples are all circumstances that indicate goodwill is more likely than not impaired.  We suggest that other indicators also be included such as the criteria in ASC 350-20-35-29b: “The most recent fair value determination resulted in an amount that exceeded the carrying amount of the reporting unit by a substantial margin.” | No | The Board should consider providing implementation guidance specifically on determining the weight of evidence from factors as this is a highly subjective process.  The examples of events and circumstances are likely to exist for an organization during any given period, and implementation guidance would be beneficial for preparers. | Yes |  | Yes |  | While the scope of this project was narrow, we would encourage the Board to expand the scope in future discussions towards other alternatives for accounting for goodwill. | 2011-05-31 13:40:38.822000
IHS Inc. | Preparer |  | Public | We are commenting on this Exposure Draft from our perspective as a preparer of financial statements.  Because a significant portion of our balance sheet is comprised of goodwill and other intangible assets, we have a particular interest in this proposed accounting standards update.  We are a leading source of information and insight in critical areas that shape today’s business landscape, including energy and power; design and supply chain; defense, risk and security; environmental, health and safety (EHS) and sustainability; country and industry forecasting; and commodities, pricing and cost.  We have been in business since 1959 and became a publicly traded company on the New York Stock Exchange in 2005.  We employ approximately 5,100 people in more than 30 countries around the world, and we generate approximately $1 billion in revenue annually. | Yes | We believe that the proposed amendments will reduce overall costs and complexity compared with existing guidance because it allows us the flexibility to evaluate our goodwill based on qualitative factors.  Historically, our quantitative analysis has resulted in the fair value of goodwill exceeding the carrying amount by a substantial margin, but we were never able to make use of the carryforward option because we couldn’t meet all of the required criteria to qualify.  We believe the proposed amendments will allow us to simplify our goodwill testing approach in the future. | Utilize qualitative assessment | We expect that we would choose to perform the qualitative assessment proposed in the guidance, since our past history indicates that the fair value of goodwill has substantially exceeded the carrying amount, and we don’t currently foresee any changes to our business that would negatively impact the difference between the two values. |  |  |  |  |  |  |  | Yes | We agree that the proposed examples of events and circumstance to be assessed are adequate, and appreciate that the examples neither exclude other potential factors to consider nor automatically result in a conclusion that the first step of the goodwill impairment test is required. | Yes | We agree that the guidance in the proposed amendments about how to assess relevant events or circumstances is clear. | Yes |  | Yes | We do not object to the proposed effective date provisions. |  | 2011-06-01 11:29:35.513000
Jones Lang LaSalle Incorporated | Preparer |  | Public | Jones [NAME] is a financial and professional services firm specializing in real estate, and our securities are registered on the New York Stock Exchange.  The firm offers integrated services delivered by expert teams worldwide to clients seeking increased value by owning, occupying or investing in real estate. With 2010 global revenue of $2.9 billion, [NAME] serves clients in 60 countries from more than 1,000 locations worldwide, including 185 corporate offices.  LaSalle Investment Management, the company’s investment management business, is one of the world’s largest and most diverse in real estate with approximately $43 billion of assets under management. | Yes |  | Utilize qualitative assessment | We expect to choose to perform the qualitative assessment proposed in the amendments. [NAME] tests its goodwill for impairment annually as required by ASC 350. Historically, our testing has ordinarily resulted in substantial margins of fair value in excess of our carrying basis, not requiring the completion of the step 2 of the annual impairment test. We believe the proposed Update would provide [NAME] with a simplified documentation and testing approach, which is the stated intention of this Update. While the costs incurred to complete the annual impairment test are generally internal employment costs, the Update would save time and efforts of our financial reporting group as well as reduce the time spent by our auditors to review our calculation.   In certain instances where a regional market is in a depressed economic state, we may choose to forego the qualitative analysis and complete the current two step quantitative analysis. We believe the option to skip immediately to the quantitative analysis in certain situations is appropriate and will further the simplification of the annual impairment documentation for all companies, public and private. |  |  |  |  |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  | We agree with the proposed effective date provisions, and we believe it would also be appropriate for the Board to expedite the issuance of the new standard for more companies to have the ability to early adopt prior of fiscal years beginning after December 15, 2011. | 2011-06-02 15:45:43.564000
[NAME] (TerreStar Corporation) | Preparer |  | Public | Satellite based mobile communication company. Less than 100 million revenue. Operating primarily in US and Canada. | Yes |  | Utilize qualitative assessment | The board basis of conclusion for cost benefit holds good during favourable economic condition and favourable business conditions, in which case, generally speaking there would not be any goodwill impairment even if we perform qantitative two steps method.  However, the proposed change does provide very little benefit in case of unfavorable economic and business condition , and ironically that is the time we may need to conserve cash and do the most of it, because we would have to go through the quatitative two step process.  So, this seems "more icing on the cake"-during good condition and "less effective" during other times when we need the most.  So, wondering is this was the completely considered by the board. |  |  |  |  |  |  |  | Yes |  |  | The events and circumstances listed in the proposed change tend to be more applicable for businesses in matured industry. We believe that it is difficult to assess these factors for emerging industry business (example: social media/group buying industry, cloud computing or software as a service (SaaS) businesses.   So suggestion is clearly to state that a company can use business specific qualitative metrics, which head of cash generating unit vouches to be important for qualitative assessment. That way, it avoids auditors disagreeing on usage of the qualitative assessment step first. | No | I would go with reasoning done by IFRS on this, that it should be applicable to small and medium enterprise.  The reasoning is that first of all, a company would see a benefit out of this proposal fully, only when business and macro conditions are favourable (as described in one of my previous comments). Secondly, the frequency of testing is annual and not quarterly, so its less streneous for public company.  Thirdly, generally speakin, goodwill is not the only item a public company has to go for valuation experts, because with current fair value requirement (FAS 157 and 159), there are various items on the balance sheet which we need valuation experts to assit. So, either ways, companies would incur the cost. On the other side, by giving an opportunity to public companies to use the qualitative assessment option during time of distress, there are more chances of company leaning towards false favorable qualitative conclusion to avoid cost and since these are principal based, it is less auditable . So, this may lead to mis-represnting or mis timing of recognition of impairment by companies. | Yes |  | In order to give greater transperancy in disclosure surrounding this,  i suggest that, pulic companies should mention in that financial statements (somewher either in notes or MD&A), if it opted for qualitative step or not, and the basis for same if it goes back and forth (using qualitative method one year and opting out the next etc.,), just so that the user would know that the company is not simply trying to play around with timing of impairment loss. | 2011-06-03 12:02:32.475000
The McGraw-Hill Companies, Inc. | Preparer |  | Public |  | Yes |  | Utilize qualitative assessment |  |  |  |  |  |  |  |  | Yes |  | Yes |  | Yes |  | Yes |  |  | 2011-06-03 13:53:11.456000
Duff & Phelps, LLC | Other, please specify | Global independent financial advisory and investment banking services firm |  |  |  |  |  |  |  |  |  |  |  |  |  | Yes | We agree with the proposed list of factors for consideration as it is not an all-inclusive list. | No | Even though the proposed guidance states that the events and circumstances should be assessed in the aggregate, we believe that the qualitative nature of the assessment will lead to potential implementation challenges.  As practice has shown, it is difficult to come to a conclusion based on an array of qualitative factors considered in their totality and attain the same level of comfort as the one provided by a quantitative analysis, which encapsulates the impact of such multiple factors.  The challenge is compounded by circumstances involving multiple reporting units and their assessment in light of total market capitalization for a publicly-traded entity. | No | Based on our experience with public registrants, we have found that audit firms and entities’ internal control procedures generally require a quantitative valuation analysis, as it provides a tangible and objective basis for an audit conclusion. This has also been evidenced by the choice of many public entities to not carry forward a fair value determination from one period to the next under ASC 350, even if the circumstances may have allowed it. | Yes |  | With regard to Question 5:  While the empirical evidence may suggest that the effect of impairments is incorporated in the price of publicly traded entities before the announcement of an impairment or a write-off, we believe that balance sheets should timely reflect such information to the best extent possible.  This is consistent with the objective of financial reporting of providing decision-useful information to investors and other users of financial statements.  Other comments:  • Paragraph 350-20-35-8A provides that the first step of goodwill impairment test is unnecessary for reporting units with zero or negative carrying amounts.  For such reporting units, one is to proceed to the second step of the test.  Perhaps the guidance should clarify that a determination of the fair value of the reporting unit is still necessary for the purpose of executing the second step of the test.  • We observe that the qualitative assessment introduces an additional step in the goodwill impairment testing process, which currently encompasses two steps.  It may therefore be simpler to re-articulate the goodwill impairment testing process in three steps. | 2011-06-06 13:37:29.920000
[NAME], CPA | Auditor |  |  |  |  |  |  |  | Nonpublic entities | 12 members, approximately 75 staff | No | The list is nice, but the accounting staff at many of my clients will be intimidated by the list just like the two-step process.  Or, they will answer "no" to one of the factors, when the answer is clearly "yes", to avoid any type of impairment analysis.  It will make more work for the auditor.  For companies (public or private) that have credentialed accounting staff, this should save some time and cost.  I really think the best approach is to mirror the approach of IFRS for SMEs, where amortization is over the estimated life or 10 years.  In the US it would make sense to use 15 years, to agree to the tax code, and thereby eliminate a potential difference for deferred tax purposes. |  |  |  | Yes | I think they are adequate, but again I think many people will answer no without really paying much attention, which will put the burden on the auditor to follow up. | Yes |  | Yes | I personally prefer accounting to be the same for all entities, with exceptions for smaller companies (less than $100M). | Yes | That is fine.  The proposed changes are not so daunting that they can't be implemented now.  Given the timing, it could be effective for 2011 year. | In many of the acquisitions I've seen of smaller companies, the Goodwill acquired is generally depleted after several years.  For smaller companies, it is easier to absorb an annual charge than the total impairment loss in one year when impairment is determined. | 2011-06-06 16:33:49.108000
Comerica Incorporated | Preparer |  | Public | Comerica Incorporated (“Comerica”) is a financial services company headquartered in Dallas, Texas. As of March 31, 2011, we are among the 20 largest U.S banking companies with total assets of approximately $55 billion, total deposits of approximately $42 billion, total loans of approximately $39 billion, and total shareholders’ equity of approximately $6 billion. | Yes | The proposed amendments would reduce overall costs and complexity associated with the goodwill impairment test by eliminating the unnecessary cost of performing valuations for those reporting units for which it is more likely than not that their respective fair value exceeds their carrying amount.  By requiring a quantitative approach (fair value calculation for each reporting unit) as the first step of the impairment test, compliance with current guidance represents significant recurring costs to [NAME], as well as many other companies, in the form of man hours from various departments and additional audit fees for the involvement of valuation experts.  Forecasts and projections needed to perform fair value calculations under the commonly used income approach often need to be more granular in nature and for time frames not typically used by the Company for internal management purposes.  This results in a significant amount of work performed for the purposes of an accounting exercise without providing much incremental decision-making value.  Our current approach for completing step one of the goodwill impairment test involves both a quantitative analysis as well as a qualitative review of the Company’s overall performance to determine the reasonableness of our conclusions.   It is our experience that an excessive amount of work is performed to support an accounting conclusion which in many periods was apparent based on qualitative analysis (e.g. periods when the fair value significantly exceeds the carrying value of the reporting units and the overall market cap of the company is significantly in excess of the book value of equity).   Comerica appreciates and supports the Financial Accounting Standards Board’s (the “Board”) continued focus to develop a cost effective approach to the goodwill impairment test.  As stated in the basis of conclusion to the current exposure draft, in developing the two-step quantitative approach during its deliberations of the Statement of Financial Accounting Standards No. 142 (“Statement 142”) the Board believed that several factors included in the guidance would limit the costs to be incurred by preparers.  However, as practice evolved such factors have not been used which has led to many companies recalculating the fair value of each reporting unit on a yearly basis.  We believe the proposed amendments represent a return to the Board’s original intent in developing Statement 142 and a step in the right direction. | Utilize qualitative assessment | As noted in earlier comments, management currently performs a qualitative analysis in conjunction with the required quantitative analysis when assessing goodwill for impairment.  Under the proposed guidance, we will simply rely on the qualitative analysis.  We routinely assess the impact of significant changes to internal and external factors on all reporting units.  We believe that the use of a qualitative assessment to determine if the first step of the impairment test is necessary will allow companies to target its focus on the reporting unit(s) considered to be at risk of failing step one (if any); thus achieving the objective of the goodwill impairment test while controlling the costs associated with the impairment test. |  |  |  |  |  |  |  | No | Comerica appreciates the Board’s efforts to provide relevant examples of events and circumstances to be included in the qualitative assessment under the proposed amendments. Further we agree with the Board that these examples should be considered in totality along with positive and mitigating events and circumstances in the overall consideration of the qualitative assessment.  However, the examples presented pertain mostly to negative events and circumstances which may suggest that the proposed amendments have an inherent negative bias.  That is to say, it could be understood that the proposed amendments place greater weight on negative events and circumstances.  We respectfully recommend that the Board considers the use of more neutral language in the description of events and circumstances to be evaluated.  For example, the description of the first example related to macroeconomic conditions can be modified to be “changes in” from “deterioration” or “limitations.”  In this example a more neutral description would clarify that both positive and negative changes to macroeconomic conditions should be considered when making a qualitative assessment. | Yes |  | Yes | As noted by the Board in the basis for conclusion, many users of the financial statements of public and nonpublic entities alike generally exclude goodwill impairment losses from their quantitative analyses.  The users of the financial statements do not discriminate between public and nonpublic entities and neither should the accounting guidance.  Also, the burden on larger public companies to perform goodwill impairment tests is comparable when considering that these entities typically have more reporting units to analyze. | Yes |  | Comerica appreciates the opportunity to comment on the Board’s Exposure Draft of a Proposed Accounting Standards Update of Intangibles—Goodwill and Other (Topic 350) issued April 22, 2010.  We support the Board’s efforts to reduce the recurring costs and complexities associated with performing the yearly goodwill impairment test required under Topic 350.    To comply with existing guidance, at a minimum companies are required to complete on a yearly basis the first step of the two-step goodwill impairment test.  While it is worth noting that performing only the first step is far less costly and complex than completing the full two-step goodwill impairment test, the fact remains that performing the first step of the goodwill impairment test nonetheless represents significant costs because of the complexities associated with calculating the fair value of each reporting unit.  In addition, it is difficult to make a case for the benefits outweighing the costs associated with such exercise given that many users of the financial statements generally exclude goodwill impairment losses from their quantitative analyses.    Comerica agrees with the addition of an assessment of qualitative factors to determine whether it is more likely than not that the fair value of a reporting unit is less than its carrying amount as a basis for determining whether it is necessary to perform the first step of the goodwill impairment test.  We consider the proposed amendments to be a natural extension of managements’ functions as they relate to assessing the impact of internal and external factors on the performance, and correspondingly the value, of reporting units.  Therefore we would welcome the opportunity to reduce the costs and complexities of the goodwill impairment where permissible after a sound assessment of relevant qualitative factors.   We thank you for the opportunity to express our support and concerns regarding this proposal, and respectfully request that the Board consider our concerns.  Should you require further information or have any questions, please do not hesitate to contact me (telephone (214) 462-6684; email address [EMAIL]; facsimile no. (214) 462-6810) or [NAME], Vice President - Accounting Policy (telephone (214) 462-6682; email address [EMAIL]; facsimile no. (214) 462-6810).  Sincerely,   /s/ [NAME] Senior Vice President and Chief Accounting Officer | 2011-06-06 21:20:32.319000
CME Group Inc. | Preparer |  | Public | CME Group is a publicly traded company that includes four registered exchanges — Chicago Mercantile Exchange Inc., the Board of Trade of the City of Chicago, Inc., the New York Mercantile Exchange, Inc. and the Commodity Exchange, Inc.  – as well as a clearinghouse, which is part of the Chicago Mercantile Exchange Inc.  CME Group’s exchanges offer derivative products based on interest rates, equity indexes, foreign exchange, energy, metals, agricultural commodities and alternative investment products to customers around the globe.  In 2010, CME Group generated $3.0 billion in revenues and had approximately $35.0 billion in total assets. | Yes | We believe that providing an option to first assess qualitative factors in determining the likelihood of impairment provides companies with an opportunity to reduce overall costs and complexity in those instances where impairment is not considered likely by preparers and their auditors. However, we believe that more cost savings would be realized if a similar qualitative assessment was made available for indefinite-lived intangible assets as these assets are generally tested in conjunction with goodwill. | Utilize qualitative assessment | Given the economic events of recent years and the Securities and Exchange Commission’s scrutiny of goodwill impairments, it has become a regular practice for prudent companies to assess goodwill qualitatively between annual test dates by examining events and circumstances closely for evidence of impairment.  We expect that there will be instances where a qualitative assessment will provide sufficient evidence to obviate a quantitative test as this has been our experience during interim periods. |  |  |  |  |  |  |  | Yes | The examples of events and circumstances are adequate when applied with the guidance presented in amended paragraphs 350-20-35-3F and 350-20-35-3G. | Yes |  | Yes | As noted in paragraph BC28, it was the Board’s intention when issuing Statement No. 142, [NAME] and Other Intangible Assets, to incorporate a carryforward option that would limit the costs incurred in assessing goodwill for impairment; however, many entities have been unable to utilize the carryforward option in practice.  We believe that the proposed amendment should be applicable to both public and nonpublic entities as it may help to align current practice with what the Board initially intended, resulting in a potential reduction in costs for all entities.  Furthermore, we believe that differences in accounting between public and nonpublic entities should be minimized as they may lead to a lack of comparability in situations that are substantially the same economically. | Yes | We agree with the proposed effective date and support the Board’s decision to allow early adoption. |  | 2011-06-07 16:05:28.527000