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In our comment letter, we support the FASB’s objective of reducing complexity when applying the variable interest entity (VIE) guidance, but recommend they pursue development of a single comprehensive consolidation model. To the extent they move forward with the targeted improvements, we believe the FASB should provide additional guidance to clarify the current model, which would reduce the cost and complexity for all companies. Further, we support the proposed changes in the determination of whether fees paid to decision makers or service providers are a variable interest.