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Comment letters to regulatory agencies

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Comment letters serve as a powerful tool for us to contribute valuable insights, expertise and recommendations.

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The assurance professionals at RSM recognize the importance of active participation in shaping industry standards and regulatory policies that govern our business landscape. Responding to standard setters and regulatory bodies, nationally and internationally, through comment letters serves as a powerful avenue for us to contribute our valuable insights, expertise, and recommendations. By engaging in this proactive dialogue, we can impact the development of fair and effective regulations that not only align with our organizational values but also foster a conducive environment for growth and innovation.

American Institute of Certified Public Accountants (AICPA)

_{June 30, 2026}

Comment letters to regulatory agencies

American Institute of Certified Public Accountants (AICPA)

Amendments to SSAE Nos. 18–19 And 21 to Reflect Proposed SSAE Common Concepts, Examination Engagements, Review Engagements, and Engagements to Report on Sustainability Information

Response Template for Exposure Draft of Proposed SSAE Common Concepts, Examination Engagements, Review Engagements, and Engagements to Report on Sustainability Information

Exposure Draft, Proposed Statement on Standards for Continuing Professional Education (CPE) Programs - September 17, 2025

Feedback on Exposure Draft, Proposed Peer Review Standards Update No. 3, Modernizing Peer Review Administration Requirements, AICPA Peer Review Board

Proposed Statement on Auditing Standards, The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements, AICPA Auditing Standards Board

Proposed Criteria for Controls Supporting Stablecoin Operations

Proposed Statement on Auditing Standards, External Confirmations, AICPA Auditing Standards Board – February 27, 2025

Proposed ASB Strategic Plan 2026–2030, AICPA Auditing Standards Board

Proposed Statement on Standards for Attestation Engagements, Scope Limitations in a Review Engagement (the proposed SSAE).

Exposure Draft, Proposed Statement on Standards for Accounting and Review Services, Applicability of AR-C Section 70 to Financial Statements Prepared as Part of a Consulting Services Engagement

Exposure Draft, Proposed Peer Review Standards Update No. 2, Reviewing A Firm’s System of Quality Management and Omnibus Technical Enhancements

Proposed Criteria for the Presentation of the Sufficiency of Assets for Redemption Specific to Asset-Backed Fiat-Pegged Tokens

Exposure Draft, Proposed new definition of publicly traded entity and revised definition of public interest entity, AICPA Professional Ethics Division – June 15, 2023

AICPA proposed new and revised interpretations related to fees (the Exposure Draft)

AICPA proposed revised interpretation Uniform CPA Examination and Continuing Professional Education

AICPA Exposure Draft, Proposed Criteria for a Description of the Content of Quality Control Materials (QCM) and the Content of QCM Related to the Relevant Standards and Interpretive Guidance

AICPA on the Exposure Draft, Maintaining the Relevance of the Uniform CPA Examination – Aligning the Exam with the CPA Evolution Licensure Model

AICPA Professional Ethics Division’s on the Exposure Draft, Proposed New and Revised Definitions and Interpretations - Compliance Audits

AICPA Professional Ethics Executive Committee on the Exposure Draft, Proposed Revisions Related to Officers, Directors and Beneficial Owners

AICPA Auditing Standards Board proposed Statement on Auditing Standards (SAS), Special Considerations – Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-to Auditors)

AICPA Auditing Standards Board proposed Statement on Auditing Standards (SAS), Amendment to AU-C Section 935

AICPA Exposure Draft, Proposed Changes to AICPA Standards for Performing and Reporting on Peer Reviews – Clarification of AICPA Standards for Performing and Reporting on Peer Reviews

California Air Resources Board (CARB)

California Air Resources Board’s (CARB) Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation

Financial Accounting Foundation (FAF)

Financial Accounting Foundation’s (FAF or Foundation) Request for Comment concerning the Foundation’s Review of the Private Company Council (PCC or Council)

Financial Accounting Standards Board (FASB)

Feedback on the Financial Accounting Standards Board’s (FASB or Board) Proposed Accounting Standards Update, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Interest Rate Risk Hedging and Net Investment Hedging (the proposed ASU or proposal).

Compensation – Retirement Benefits – Defined Benefit Plans – Pension (Subtopic 715-30): Discount Rate Used to Measure the Benefit Obligation for Certain Market-Return Cash Balance Plans

Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Fair Value Measurement (Topic 820): Investment Companies with Equity Securities Subject to Contractual Sale Restrictions (proposed Update or proposal).

Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Equity (Topic 505): Initial Measurement of Paid In-Kind Dividends on Equity-Classified Preferred Stock (the proposed Update)

Feedback on the Financial Accounting Standards Board (FASB or Board) 2025 Invitation to Comment (ITC)

Feedback on the Financial Accounting Standards Board’s (FASB or Board) Proposed Accounting Standards Update, Codification Improvements, (the proposed ASU or proposal)

Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Environmental Credits and Environmental Credit Obligations (Topic 818) (proposed Update or proposal)

Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Interim Reporting (Topic 270)-Narrow-Scope Improvements (proposed Update or proposal)

Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Government Grants (Topic 832): Accounting for Government Grants by Business Entities (proposed Update or proposal)

Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software (proposed Update or proposal)

Feedback on the Financial Accounting Standards Board’s proposed Accounting Standards Update (ASU), Business Combinations (Topic 805) and Consolidation (Topic 810): Determining the Accounting Acquirer in the Acquisition of a Variable Interest Entity.

Feedback on the Financial Accounting Standards Board’s (FASB or Board) proposed Accounting Standards Update (ASU), Derivatives and Hedging (Topic 815): Hedge Accounting Improvements (proposed Update).

Comments on the Public Company Accounting Oversight Board’s (PCAOB) Proposed Auditing Standard – Designing and Performing Substantive Analytical Procedures and Amendments to Other PCAOB Standards.

Comments on FASB's proposed Accounting Standards Update (ASU), Derivatives and Hedging (Topic 815) and Revenue from Contracts with Customers (Topic 606): Derivatives Scope Refinements and Scope Clarification for a Share-Based Payment from a Customer in a Revenue Contract (proposed Update).

Accounting Standards Update, Debt—Debt with Conversion and Other Options (Subtopic 470-20): Induced Conversions of Convertible Debt Instruments

Proposed Statement of Financial Accounting Concepts - Concepts Statement No. 8, Conceptual Framework for Financial Reporting Chapter 6: Measurement

FASB proposed Income Statement - Reporting Comprehensive Income = Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses

FASB proposed Accounting Standards Update (proposed ASU), Financial Instruments—Credit Losses (Topic 326), Purchased Financial Assets

FASB proposed Accounting Standards Update (ASU), Compensation—Stock Compensation (Topic 718): Scope Application of Profits Interest Awards (proposed Update or proposal)

FASB proposed Accounting Standards Update (ASU), Intangibles—Goodwill and Other—Crypto Assets (Subtopic 350-60), Accounting for and Disclosure of Crypto Assets

FASB proposed Accounting Standards Update (ASU), Income Taxes (Topic 740): Improvements to Income Tax Disclosures (proposed Update or proposal)

FASB proposed Statement of Financial Accounting Concepts - Concepts Statement No. 8, Conceptual Framework for Financial Reporting Chapter 5: Recognition and Derecognition

FASB proposed Statement of Financial Accounting Concepts - Concepts Statement No. 8, Conceptual Framework for Financial Reporting Chapter 2: The Reporting Entity

FASB proposed Accounting Standards Update, Leases (Topic 842): Common Control Arrangements

FASB Accounting Standards Update Business Combinations—Joint Venture Formations (Topic 805-60): Recognition and Initial Measurement

FASB proposed Accounting Standards Update, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures (proposed Update or proposal)

FASB Accounting Standards Update, Investments–Equity Method and Joint Ventures (Topic 323): Accounting for Investments in Tax Credit Structures Using the Proportional Amortization Method

FASB proposed Accounting Standards Update, Reference Rate Reform (Topic 848) and Derivatives and Hedging (Topic 815): Deferral of the Sunset Date of Topic 848 and Amendments to the Definition of the Secured Overnight Financing Rate Overnight Index Swap Rate

FASB proposed Accounting Standards Update, Liabilities—Supplier Finance Programs (Subtopic 405-50): Disclosure of Supplier Finance Program Obligations

FASB proposed Accounting Standards Update, Interim Reporting (Topic 270): Disclosure Framework—Changes to Interim Disclosure Requirements

FASB’s proposed Accounting Standards Update, Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures

Governmental Accounting Standards Board (GASB)

GASB revisions in the 2023 Exposure Draft

Public Company Accounting Oversight Board (PCAOB)

Draft 2026-2030 Strategic Plan Goals and Objectives, PCAOB Release No. 2026-006

Request for Public Comment on PCAOB Standard Setting, PCAOB Release No. 2026-05

Proposed Rule, Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies, File Number S7-2026-18

Proposed amendments to QC 1000, a firm’s system of quality control, and related rules and forms, Docket Matter No. 057

Proposed Rule- 33-11414, Semiannual Reporting, File Number S7-2026-15.

PCAOB Strategic Priorities, PCAOB No. 2026-001

Securities and Exchange Commission [Release No. 34-101723; File No. PCAOB-2024-07] Public Company Accounting Oversight Board; Notice of Filing of Proposed Rules on Firm Reporting; PCAOB Rulemaking Docket Matter No. 055

Securities and Exchange Commission [Release No. 34-101724; File No. PCAOB-2024-06] Public Company Accounting Oversight Board; Notice of Filing of Proposed Rules on Firm and Engagement Metrics and Related Amendments to PCAOB Standards; PCAOB Rulemaking Docket Matter No. 041

Comment Letter on PCAOB Rulemaking Docket Matter No. 56

Comments on the final standard adopted by the PCAOB on A Firm’s System of Quality Control and Related Amendments to PCAOB Standards

Comments on the PCAOB's (PCAOB or the board) Firm Reporting (the proposal)

Comments on the PCAOB's Firm and Engagement Metrics.

Proposals Regarding False or Misleading Statements Concerning PCAOB Registration and Oversight and Constructive Requests to Withdraw from Registration

Roundtable Discussion of Proposed Amendments to PCAOB Auditing Standards Related to a Company’s Noncompliance with Laws and Regulation

PCAOB proposed Amendments Related to Aspects of Designing and Performing Audit Procedures that Involve Technology-Assisted Analysis of Information in Electronic Form (the proposal, the release)

PCAOB Auditing Standards related to a Company’s Noncompliance with Laws and Regulations And Other Related Amendments

PCAOB proposed Auditing Standard, General Responsibilities of the Auditor in Conducting an Audit, and Proposed Amendments to PCAOB Standards (the proposed standard)