PCFRC comment letter addresses effective date for new FIN 48 standard

The Private Company Financial Reporting Committee (PCFRC) discussed their final comment letter on FSP FIN 48-d, Application Guidance for Pass-Through Entities and Tax-Exempt Not-for-Profit Entities and Disclosure Modifications for Nonpublic Entities, at their most recent meeting.

The PCFRC, a joint effort of FASB and the AICPA, basically plans to approve what FASB has done. The committee, however, plans to ask FASB to further clarify the effective date of the standard in the comment letter.

The comment deadline was June 17. In the proposed statement, the guidance would be effective upon issuance for entities that already apply FIN 48, and upon adoption of Interpretation 48 for entities that have deferred the application of FIN 48. Certain nonpublic entities may defer the effective date to the annual financial statements for fiscal years beginning after Dec. 15, 2008.

Thomas J. Groskopf, CPA, a director with Barnes, Dennig & Co. in Cincinnati and a member of the PCFRC, stressed that FASB is indicating there will be no further FIN 48 deferrals. “This is the year that most private companies need to adopt FIN 48,” Groskopf told a crowd of more than 600 OSCPA members at the OSCPA Members Summit on June 30 in Columbus.

Groskopf also warned attendees to watch for FASB’s project on financial statement presentation. “This is a very big area that should prove to be very expensive for private companies,” Groskopf said.

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