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Deloitte Comment Letters

Proposed FASB Staff Positions

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FAS 13-a, "Accounting for a Change or Projected Change in the Timing of Cash Flows Relating to Income Taxes Generated by a Leveraged Lease Transaction"FAS 13-b, "Accounting for Rental Costs Incurred during a Construction Period"FAS 19-a, "Accounting for Suspended Well Costs" FAS 107-a, "Disclosures About Certain Financial Assets: An Amendment of FASB Statement No. 107"FAS 107-b and APB 28-a, "Interim Disclosures About Fair Value of Financial Instruments"FAS 115-a, FAS 124-a, and EITF 99-20-b, "Recognition and Presentation of Other-Than-Temporary Impairments"FAS 109-b, "Accounting and Disclosure Guidance for the Foreign Earnings Repatriation Provision within the American Jobs Creation Act of 2004"FAS 117-a, "Endowments of Not-for-Profit Organizations: Net Asset Classification of Funds Subject to an Enacted Version of the Uniform Prudent Management of Institutional Funds Act, and Enhanced Disclosures"FAS 123(R)-a, "Classification and Measurement of Freestanding Financial Instruments Originally Issued as Employee Compensation"FAS 123(R)-b and FAS 123(R)-cFAS 123(R)-d, "Classification of Options and Similar Instruments Issued as Employee Compensation That Allow for Cash Settlement Upon the Occurrence of a Contingent Event"FAS 123(R)-e, "Amendment of FASB Staff Position FAS 123(R)-1"FAS 128-a, "Computational Guidance for Computing Diluted EPS Under the Two-Class Method"FAS 131-a, "Determining Whether Operating Segments Have 'Similar Economic Characteristics' under Paragraph 17 of FASB Statement No. 131, Disclosure about Segments of an Enterprise and Related Information"FAS 132(R)-a, "Employers' Disclosures About Postretirement Benefit Plan Assets"FAS 133-a, "Accounting for Unrealized Gains (Losses) Relating to Derivative Instruments Measured at Fair Value Under Statement 133"FAS 133-b and FIN 45-c, "Disclosures About Credit Derivatives and Certain Guarantees: An Amendment of FASB Statement No. 133 and FASB Interpretation No. 45"FAS 140-b, "Application of EITF Issue No. 85-24, Distribution Fees by Distributors of Mutual Funds That Do Not Have a Front-End Sales Charge, When Future Distribution Fees Are Sold to Unrelated Third Parties"FAS 140-c, "Clarification of the Application of Paragraphs 40(b) and 40(c) of FASB Statement No. 140"FAS 140-d, "Accounting for Transfers of Financial Assets and Repurchase Financing Transactions"FAS 140-e and FIN 46(R)-e, "Disclosures about Transfers of Financial Assets and Interests in Variable Interest Entities"FAS 141-b, 142-e, and 144-b, "Fair Value Measurements in Business Combinations and Impairment Tests"FAS 141(R)-a, "Accounting for Assets Acquired and Liabilities Assumed in a Business Combination That Arise From Contingencies"FAS 142-c, "Application of FASB Statement No. 142, Goodwill and Other Intangible Assets, to Exchange Memberships"FAS 142-d, "Amortization and Impairment of Acquired Renewable Intangible Assets"FAS 142-f, "Determination of the Useful Life of Intangible Assets"FAS 143-a, "Accounting for Electronic Equipment Waste Obligations"FAS 144-c, "Classifying and Accounting for a Depreciable Asset as Held-for-Sale When an Equity Method Investment Is Obtained"FAS 144-d, "Amending the Criteria for Reporting a Discontinued Operation"FAS 154-a, "Considering the Effects of Prior-Year Misstatements When Quantifying Misstatements in Current-Year Financial Statements"FAS 157-b, "Effective Date of FASB Statement No. 157"FAS 157-c, "Measuring Liabilities Under FASB Statement No. 157"FAS 157-e, "Determining Whether a Market Is Not Active and a Transaction Is Not Distressed"FAS 157-f, "Measuring Liabilities Under FASB Statement No. 157"FAS 157-g, "Estimating the Fair Value of Investments in Investment Companies That Have Calculated Net Asset Value per Share in Accordance With the AICPA Audit and Accounting Guide, Investment Companies"FAS 158-a, "Conforming Amendments to the Illustrations in FASB Statements No. 87, No. 88, and No. 106 and to the Related Staff Implementation Guides"FIN 39-a "Amendment of FASB Interpretation No. 39"FIN 45-b, "Application of FASB Interpretation No. 45 to Minimum Revenue Guarantees Granted to a Business or Its Owners"FIN 46(R)-b, "Implicit Variable Interests Resulting from Related Party Relationships under FASB Interpretation No. 46 (revised December 2003), Consolidation of Variable Interest Entities"FIN 46(R)-c, "Determining the Variability to Be Considered in Applying FASB Interpretation No. 46(R)"FIN 46(R)-d, "Application of FASB Interpretation No. 46(R) to Investment Companies"FIN 48-a, "Definition of Settlement in FASB Interpretation No. 48"FIN 48-d, "Application Guidance for Pass-Through Entities and Tax-Exempt Not-for-Profit Entities and Disclosure Modifications for Nonpublic Entities"EITF 85-24-a, "Application of EITF Issue No. 85-24 When Cash for the Right to Future Distribution Fees for Shares Previously Sold Is Received from Third Parties"EITF 00-19-a, "Application of EITF Issue No. 00-19, 'Accounting for Derivative Financial Instruments Indexed to, and Potentially Settled in, a Company's Own Stock,' to Freestanding Financial Instruments Originally Issued as Employee Compensation"EITF 03-6-a, "Determining Whether Instruments Granted in Share-Based Payment Transactions Are Participating Securities"APB 14-a, "Accounting for Convertible Debt Instruments That May Be Settled in Cash Upon Conversion (Including Partial Cash Settlement)"APB 18-a, "Accounting by an Investor for its Proportionate Share of Other Comprehensive Income of an Investee Accounted for under the Equity Method in Accordance with APB Opinion No. 18, The Equity Method of Accounting for Investments in Common Stock, upon a Loss of Significant Influence"TB 85-4-a, "Accounting for Life Settlement Contracts by Investors"AAG INV-a, "Reporting of Fully Benefit-Responsive Investment Contracts Held by Certain Investment Companies Subject to the AICPA Investment Company Guide"AUG AIR-a, "Accounting for Planned Major Maintenance Activities"SOP 90-7-a, "An Amendment of AICPA Statement of Position 90-7"SOP 94-6-a, "Nontraditional Loan Products"SOP 07-1-a, "Effective Date of AICPA Statement of Position 07-1"