We also support the four principal reasons FASB cited for issuing the new proposal:
(1) addressing concerns of users and others that the use of the intrinsic value method
results in financial statements that do not faithfully represent economic transactions,
which can distort the financial condition and operations of the issuer; (2) improving
the comparability of reported financial information through the elimination of
alternative accounting methods; (3) simplifying U.S. generally accepted accounting
principles by requiring the use of a single method of accounting for share-based
payment; and (4) enabling international convergence and greater international
comparability in the accounting for share-based payment.
We appreciate your consideration of our comments and would be pleased to further
discuss these issues at your convenience.
David M. Walker
Comptroller General
of the United States

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