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Letter to FASB on Subtopic 220-40

December 10, 2024 

FASB
Technical Director 
801 Main Avenue 
PO Box 5116 
Norwalk, CT 06856-5116. 

Sent via email to [email protected] 

File Reference No. 2024-ED800 

RE: Exposure Draft Income Statement — Reporting Comprehensive Income — Expense Disaggregation Disclosures (Subtopic 220-40) 

Clarifying the Effective Date 

Dear Technical Director: 

The Virginia Society of CPAs (VSCPA) Accounting & Auditing Advisory Committee (Committee) has reviewed the Exposure Draft Income Statement — Reporting Comprehensive Income — Expense Disaggregation Disclosures (Subtopic 220-40) Clarifying the Effective Date (ED), issued by the Financial Accounting Standards Board (FASB). The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of all CPAs and their profession by communicating information and vision, promoting professionalism, and advocating members’ interests. The VSCPA membership consists of nearly 12,000 individual members who actively work in public accounting, private industry, government, and education. 

The Committee agrees with the clarification of the effective date. It was clearly the Board’s intent in the basis for conclusions of Update 2024-03 that all public business entities should initially adopt the disclosure requirements in the first annual reporting period beginning after Dec. 15, 2026, and interim reporting periods within annual reporting periods beginning after Dec. 15, 2027. This ED removes any remaining ambiguity. 

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The VSCPA appreciates the opportunity to respond to this ED. Please direct any questions or concerns to VSCPA Vice President, Advocacy & Pipeline Emily Walker, CAE, at [email protected] or (804) 612- 9428. 

Sincerely,   

Michael Phillips, CPA
Chair 2024-2025  
VSCPA Accounting & Auditing Advisory Committee 


VSCPA Accounting & Auditing Advisory Committee 2024-2025 

Michael Phillips, CPA —Chair 
Daniel Martin, CPA — Vice Chair 
Zach Borgerding, CPA 
Joshua Keene, CPA   
Nick Kinsler, CPA  
Brian Minor, CPA 
Elisa Obillo, CPA 
Krisia Raya, CPA 
Charles Valadez, CPA  
Natalya Yashina, CPA