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AGC Filing Comments on FASB Multiemployer Disclosure Draft

AGC is finalizing its comments on the Federal Accounting Standards Board's proposed accounting standard that would require the disclosure of withdraw liability from multiemployer pension plans on company financials. AGC's comments urge FASB to withdraw the Exposure Draft and reconsider the proposal. AGC's concerns with the Exposure Draft (ED) are extensive. The draft under-appreciates the costs associated with compliance and overestimates the relevancy of the information that would be provided if the ED were to go into effect as written.  Any information included will be neither timely nor accurately reflective of the financial impact of participating in a multiemployer plan.  The draft significantly underestimates the complexity of the relationship between employers and multiemployer plans, and significantly underestimates the importance of the construction industry exemption that makes almost any liability merely theoretical rather than material.  Comments on the exposure draft are due Monday, November 1, 2010. If you are interested in sending your own letter to the FASB, please keep in mind the following guidelines:
  • Deadline is Monday, November 1, 2011.
  • The FASB will not consider form letters.  Comments should be thoughtful and individually written.
  • Letters can be mailed or emailed to the following addresses:
Technical Director File Reference No. 1860-100 Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT  06856-5116 Email: director@fasb.org (For emailed letters, please include "Comment Letter - File Reference No. 1860-100" in the subject line of the email.)