We appreciate the opportunity to comment on the FASB 450 Exposure Draft. Our comments focus on proposed amendments with respect to paragraphs 715-80-35-2 and 715-80-50-2 regarding multiemployer plans. We request that the Board withdraw the amendments or offer clarifications in accordance with our concerns set forth below.
As end-users of employer audited financial statements, we have a unique view with respect to the proposed increase in disclosure. While we generally applaud an increase in transparency regarding an employer’s potential liability with respect to multiemployer plans, we believe that the proposed amendments will provide misleading information to end-users that will impair, not enhance, our member’s ability to determine the financial capital, character, and capacity of construction employer’s who seek surety bonding. We are not aware of any entity in the surety bond industry that has requested or suggested that FASB amend its standards as set forth in the Exposure Draft.
NASBP Letter Addressing Locality Requirements in VA Bid Bond