CCR, CFIT, CGB, COT and CPC updates.

Committee on Corporate Reporting (CCR)

Staff Liaison: Christine DiFabio

CCR held a quarterly meeting on December 14-15, in Washington, D.C., co-located with FEI's Committee on Finance and Technology, (CFIT). The meeting included sessions with representatives from the U.S. Securities and Exchange Commission (SEC), the Public Company Accounting Oversight Board (PCAOB) and the Big Four public accounting firms.

* SEC representatives: Chief Accountant Conrad Hewitt, Deputy Chief Accountant Scott Taub and Chief Accountant, Division of Corporation Finance, Carol Stacey. Among the topics discussed: the SEC's proposed rules on management guidance for implementing Section 404 on internal controls, FIN 48 implementation issues, XBRL initiatives and 2006 year-end reporting focus.

* PCAOB representatives: Chief Auditor Tom Ray, Deputy Chiefs Laura Phillips and Jennifer Rand and Carl Calendar with the Inspections area. Among the discussion topics: PCAOB 2007 standard-setting agenda, revised audit standard implementing Section 404 on internal controls, project work on client-privilege issues, as well as concerns regarding timing of PCAOB inspections.

* FASB Board Member George Batavick provided an update on current FASB projects, including FIN 48-related implementation issues, the conceptual framework, business combinations and others.

Comment Letters: CCR is developing comment letters in response to the following issues:

-- to FASB in response to its Exposure Draft, Disclosures about Derivative Instruments and Hedging Activities--an amendment of FASB Statement No. 133 (comments due by March 2, 2007).

-- to the SEC in response to its proposed rule for Management Guidance related to implementing the requirements of Section 404 on internal control (comments due on February 26).

-- to the PCAOB in response to its proposed revised auditing standard for implementing the requirements of Section 404 on internal control (comments due on February 26).

Find comment letters at www.fei.org; click on "financial reporting" in left margin, then click on "comment letters."

Committee on Finance and Information Technology (CFIT)

Staff Liaison: Bill Sinnett

CFIT's meeting was co-located with FEI's Committee on Corporate Reporting (CCR) in Washington, D.C., on December 14 and 15. Neal Hannon, director, Financial Reporting Technologies, for the Financial Accounting Foundation (FAF), joined CFIT Chair Taylor Hawes and Vice Chair Bill Overell in a presentation to CCR members on developments and plans for expanding extensible Business Reporting Language (XBRL).

Other presentations included: "The SEC's IT Strategic Plan: 2007-12," by Corey Booth, CIO at the SEC; "Trends in Finance and Accounting Outsourcing," Mike Beals and Jodi Keppler, both with EquaTerra and Kent Burkhardsmeier, of Microsoft; and "XBRL: An Investor's Perspective," Tom Larsen of the CFA Centre for Financial Market Integrity.

CFIT's next meeting will focus on outsourcing--one of the committee's major initiatives--and will be hosted by Bob Shultz, vice president of Internal Audit for the Hewlett-Packard Co., on March 21 and 22, at HP's outsourcing facility in San Jose, Costa Rica.

Committee on Government Business (CGB)

Staff Liaison: Mark Prysock

Issue: Pension Reform and Government Contracts. Congress recently enacted sweeping pension reform legislation (H.R. 4), which has been sent to the President for his signature. The next step in the process will be for the Administration to begin drafting regulations implementing the legislation.

CGB Action: CGB has expressed great concern that the legislation does not adequately account for government contractors, especially those who have fixed-price contracts with the government. In short, the discrepancies between the cost accounting standards (which govern if and when contractors may be reimbursed by the government for certain outlays, such as pension fund contributions) and ERISA have placed financial strain on government contractors. The recently-enacted Pension Protection Act will only exacerbate these differences by increasing current pension funding obligations.

CGB recently submitted a letter to the Cost Accounting Standards Board Working Group, highlighting those issues which it feels should be addressed during the regulation-writing period.

Committee on Taxation (COT)

Staff Liaison: Mark Prysock

Issue: Non-Qualified Deferred Compensation. In late January, the Senate Finance Committee approved S. 349, the "Small Business and Work Opportunity Act of 2007."

COT Action: In correspondence with Congressional leadership, COT has opposed the proposal, arguing that the tax code is nether an appropriate nor an effective vehicle for regulating compensation levels. It added that the proposal would add a layer of complexity and an already complex area, and would almost certainly create administrative and enforcement problems for both the IRS and companies. COT noted that the SEC was the appropriate agency to oversee executive compensation.

[ILLUSTRATION OMITTED]

Committee on Private Companies (CPC)

Staff Liaison: Serena Davila

* The CPC Policy Subcommittee is seeking a few new members. This subcommittee is responsible for monitoring and developing private company positions on legislation, regulations and other public policy initiatives that impact privately held companies.

The subcommittee and FEI staff are the primary private company resources for drafting comment letters and position papers, and developing the agenda for meetings on Capitol Hill. To join the subcommittee or learn more, contact Serena Davila at [e-mail] or 202.626.7809.

* The Policy Subcommittee is planning a Washington, D.C. "fly-in" April 23-25 to visit Capitol Hill and discuss legislative bills important to private companies. Two of the issues the subcommittee plans to raise with legislators are S Corp reform and the Interest Charge-Domestic International Sales Corporation (IC-DISC) issue. In addition, the subcommittee plans to discuss health-cost containment and small business health plans. Legislation is still in the works for these two issues in the 110th Congress.

* The Spring Private Company Forum will be held March 8-9 in Las Vegas, and plans are in the works for the Fall Private Company Forum, in October, at the Ritz-Carlton in St. Louis.