Miller & Bahnson should follow their own adviceMiller and Bahnson advise Financial Executives International and the Institute of Management

Accountants to "Be careful what you ask for" (Accounting Today, Feb. 27-March 19, 2006, page 12).

I suggest that they follow their own advice and be more careful in what they write.

They establish their credentials by reminding us that they both worked at the Financial Accounting Standards Board many years ago. I worked there too, a little more recently and quite a bit longer. I acknowledge their right to be critical of those who do not agree with all that FASB does, but their criticisms lack the neutrality that the board tries hard to achieve in its own standard-setting process.

The piece in question begins by characterizing a joint comment letter from FEI and the IMA as "unsolicited," yet FASB had published the draft business combinations standard on its Web site many months earlier and had invited interested parties to comment before the issuance of an exposure draft.

Unfortunately, few parties were willing to devote the time and effort to comment in depth on what was not yet even an actual proposal. But that hardly justifies criticizing those who would be most affected by this project and wanted FASB to hear their thinking as early as possible.

Subsequent to the issuance of the exposure draft, numerous other parties weighed in on this controversial project, many with strong opinions that disagreed with FASB. This included FEI and the IMA again, many other business organizations, accounting firms, financial analysts and others, and even yours truly. I expressed reservations about some aspects of the proposal, but supported others. Additionally, I submitted personal comments on closely related projects on consolidation policy and the recent paper on assets and liabilities with uncertainties.

All of these projects potentially involve fundamental changes to accounting. I think that FASB doesn't have it quite right on certain aspects of these projects, but I trust that my comments and those from others will allow the board members to reach final conclusions that will truly improve financial accounting. That's the nature of due process - all interested parties should participate, and it's reasonable to expect that they will be self-interested in the views they express. Rather than taking pot shots at the constructive critics of FASB's process, I wish that Miller and Bahnson would expend the same energy in writing their own comments to the board.

By the way, I am a member of the IMA's Financial Reporting Committee, as well as an observer to the FEI Committee on Corporate Reporting. I don't agree with all that those organizations say, but I sincerely believe that the process of setting financial accounting standards is greatly improved by having all interested parties participate to the greatest extent possible. Rather than living in the good old days of the 1970s and 1980s, I believe that it's important to keeping trying to do better all the time.

Dennis R. Beresford

Ernst & Young Executive Professor of Accounting

University of Georgia

Editor's note: Dennis Beresford served as chairman of FASB from 1987 to 1997.

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