Bp April 12 2010 Presentation Accounting Principles Under Development What Is Convergincg On You...

Barrett Peterson, CPA Illinois CPA SocietyManager, Accounting Standards, North Shore Chapter Procedures, & Analysis Industry & BusinessTTX [email protected] April 12, 2010

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FASB AND IASB CONVERGENCE PROJECTS

Common Goal – Recognize the global nature of financial markets’ need for high-quality, globally comparable financial information to meet the needs of investors and other providers of capital.

Common base – high quality accounting standards that provide relevant, transparent, neutral and comparable financial information.

General Applicability Reminders: FASB: Applicable to nongovernmental entities, including not-for-

profit entities. GASB applies to governmental entities. IASB: Applicable to general purpose financial reporting by profit-

oriented entities Other entities may find IFRS appropriate [Preface to IFRS]

CONVERGENCE – A BRIEF HISTORY

FASB Term Net Income Plan, Program, Process,

or Group of Activities Amortized Accruals Capital Lease

IASB Term Profit & Loss, or Net

Income Scheme

Amortised Provisions Finance Lease

Norwalk Agreement – 2002 2006 Memorandum of Understanding [MOU] –

A Roadmap for Convergence: 2006-2008 2008 Memorandum of Understanding [MOU] –

Progress Report and Timetable for Completion 2009 (November 5) Update to Memorandum

of Understanding and Reaffirmation of Memorandum of Understanding [MOU]

2010 SEC includes the status of convergence as a consideration in 2011 “roadmap” decision

Contract focus – the assets and liabilities have a conceptual net position

Assets [rights] and liabilities [performance obligations] a core focus, plus cash flows [much less emphasis on income statement]

Revenue reflects the increase in the net contract position, either by increases in consideration or satisfaction of performance obligations

FASB much more focused on fair value measurement; IASB greater use of carrying value/amortized cost

FASB “recycles” OCI; IASB does not in all cases

A Conceptual Framework Project: A proposed Concept Statement regarding the Reporting Entity issued March 11, 2010

Fourteen Standards Projects, three of which are inactive

A Research Project, on Financial Instruments: Derecognition

The Conceptual Framework Project, comprised of four components: Objective and Quality Characteristics Reporting Entity: FASB issues a Proposed

Statement of Financial Accounting Concepts on March 11, 2010

Measurement Elements and recognition

Reporting Discontinued Operations, 2010 Accounting for Financial Instruments, 2010 Fair Value Measurement, 2010 Statement of Comprehensive Income, 2010 Consolidations: Policy and Procedures, 2010 Emissions Trading Schemes, 2011 Financial Instruments With Characteristics

of Equity, 2011

Financial Statement Presentation, 2011 Insurance Contracts, 2011 Leases, 2011 Revenue Recognition, 2011 Earnings per Share [not active] Income Taxes [not active] Postretirement Benefit Obligations

including Pensions (phase 2) [not active]

Lessee Accounting Capitalize a “right to use” asset Recognize a debt, or payable for short-term leases

Lessor Accounting Reflect a receivable for amounts due under the

contract Reflect “performance obligation” accounting for an

initially deferred credit Fundamental Conceptual Change – “Operating”

Lease concept no longer exists for lessees A schedule M will arise, probably producing a

deferred tax asset subject to valuation allowance consideration

Lease defined a contract to convey a right to use a specified asset, for a period of time, for consideration

Certain items excluded Leases of intangible assets Leases to explore for natural resources Leases of biological assets Contracts that represent a purchase (lessee) or sale

(lessor) of the underlying asset Leases outstanding at time of adoption recorded as an

obligation and related asset [lessee], or a receivable and related performance obligation [lessor]

Recognition when the contract is signed, and presented net in financial statements until delivery

Statement of Financial Position Significant increase in assets Significant increase in debt obligations

Income Statement – timing of expense recognition Depreciation plus interest expense under new standard Lease rental expense is straight line amounts as lease Amortization life vs. similar asset’s depreciable life

Financial ratios Capitalization ratios Interest coverage calculation

Covenant requirements – debt agreements, leases, and other financial instruments terms

Lessee Disclosure Requirements – the Lease Obligation “Debt” footnote Description of leasing activities, including disaggregated data by nature or function Use, and amounts reflected, for simplified accounting for short-term leases Disclosure of any sale and leaseback transactions A maturity analysis of the gross obligation to pay rentals, with a reconciliation of the gross obligation to

obligation amounts presented in the financial statements A reconciliation between opening and closing balances for its right-of-use assets and its obligation to pay

rentals A narrative description of its assumptions and estimates on the amortization method used, options,

contingent rentals, residual value guarantees, and the discount rate used

Lessor Transitional Provisions Recognize and measure all outstanding leases at initial application using a simplified retrospective

approach at the present value of remaining lease payments, discounted at the original rate the lessor is charging the lessee. The performance obligation should be measured on the same basis as the receivable.

IFRS users should reinstate previously derecognized lease assets at depreciated cost, adjusted for impairments and revaluations.

Measurement and Initial Recognition – to be done at the inception of the lease Lessor Accounting for Residual Value Guarantees

Include amounts payable in the lease receivable if they can be measured reliably Measure the lease receivable using the expected outcome technique Reassess the carrying amount of the receivable at each reporting date for new facts or circumstances

materially changing the receivable Changes to the receivable from changes in residual value guarantees treated as an adjustment to the

lessor’s receivable and related performance obligation liability

March 3, 2010: Joint Boards tentatively decide to indicate their preference for requiring an entity to adopt these changes on a full retrospective basis

Format designed around sections and categories which are similar – but not identical to - current cash flows statement sections

Focus substantially emphasizes the sections, and some categories, causing the balance sheet to not balance

Some emerging difference between FASB and IASB requirements

Not-for profit entities and Benefit Plans excluded from scope

Extensive changes to financial statement format, components, presentation, and related disclosures, based on three core objectives: Cohesive presentation of financial information Disaggregation of information to make it useful to

enable investors to assess the amount, timing, and uncertainty of future cash flows

Present information to permit users to evaluate liquidity and financial flexibility of the entity to assess its ability to meet financial commitments and invest in business opportunities

Align financial statement categories and line items across all financial statements

Employ a presentation approach based on how management views and directs the business

Present information about discontinued operations separate from continuing business activities

Classify assets and liabilities to best reflect how they are used by the entity

Present meaningful subtotals

Statement of Financial Position Statement of Comprehensive Income,

separated into profit and loss/net income and other comprehensive income

Statement of Cash Flows Statement of Changes in Equity An analysis presenting a “roll-forward” of

all significant asset and liability line items

The Statements of Financial Position, Comprehensive Income, and Cash Flows to share a common set of categories: Business Section

Operating Category – the entity’s core purpose, including capital expenditures

Investing Category – not related to core business, such as available-for-sale securities held by a manufacturer

Financing arising from operating activities Financing Section – how the entity is funded Income Taxes Discontinued Operations – net of taxes Equity Example: FASB Handout

Statement of Financial Position Assets and Liabilities grouped by category –

business [operating and investing], financing, income taxes, and discontinued operations.

Totals by category Total Assets and Total of Liabilities and Equity

reported, but does not “foot” to “balance” Recommend sequence of presentation within

section/category by liquidity if appropriate

Present by section – operating, investing, financing, income taxes, discontinued operations

Disaggregate each section by function, or by nature if more informative

Disaggregate functional amounts by nature to the extent this will enhance usefulness in predicting the entity’s future cash flow

Direct method presentation required Operating cash flows different –

Current operating cash flows Capital expenditures included Investing activities included

Financing section – Entity debt and equity Income taxes section now a component Discontinued operations now a component

Accounting policies should describe the entity’s classification policy

An entity with an operating cycle longer than a year should describe its operating cycle in the footnotes

Repatriation limitations and other restrictions on cash and short-term equivalents should be disclosed

Roll-forward of all significant asset and liability line items [not required for US nonpublic business entities]

A roll-forward analysis of each significant asset and liability line item is required, and must distinguish [columns]: Changes due to cash inflows and outflows Changes from repetitive and routine noncash accruals Changes from noncash transactions or events that are

nonroutine or nonrepetitive [acquisition or disposition of a business, for example]

Changes resulting from accounting allocations [depreciation, for example]

Changes resulting from accounting provisions/reserves [bad debts, obsolete inventory, for example]

Changes resulting from remeasurements

Remove inconsistencies and weaknesses in existing revenue recognition standards and practices

Provide a more robust framework for addressing revenue recognition issues

Simplify financial reporting by reducing the number of standards to which companies must refer

Improve comparability across companies and geographical boundaries

Revenue recognition to reflect a contract-based recognition model. Under a contract, the company Obtains rights to consideration (payment) from

customers Assumes ”performance obligations” to provide goods

and services to the customer Revenue is recognized when performance

obligations are satisfied Revenue amounts for each performance obligation

based on an allocation of the customer’s consideration

Performance obligations to be remeasured if subsequently evaluated as “onerous”

Lease contracts Insurance contracts Financial instrument contracts Guarantees (other than product

warranties) within the scope of other standards

Identify the contract with the customer Identify and separate performance obligations in the

contract Determine and, if appropriate, allocate the transaction

consideration Recognize revenue as performance obligations are

satisfied Record amortizable asset for contract fulfillment costs,

subject to impairment, expensed as performance obligations are satisfied

Expense contract acquisition costs, costs related to satisfied performance obligations, and abnormal amounts of wasted labor, material or other fulfillment costs

Transaction consideration determination Variable consideration Collectability Time value of money Noncash consideration

Revenue recognition Customer control of goods and services Continuous transfer of goods and services Other considerations –

Principal vs. agent Options to acquire additional goods and services Licenses and rights to use Rights of return Product warranties and product liabilities; quality assurance warranties

vs. insurance warranties

Reconsider the recognition and measurement of financial instruments

Address issues related to impairment of financial instruments and hedge accounting

Increase convergence in accounting for financial instruments

Simplify and resolve practice issues in accounting for hedging activities

Improve the financial reporting of hedging activities to make the accounting model and associated disclosures easier to understand for users of financial statements

Address differences in the accounting for derivative instruments and hedged items or transactions

Cash, evidence of an ownership interest in an entity, or a contract that both: Imposes on one entity a contractual obligation either:

To deliver cash or another financial instrument to a second entity To exchange other financial instruments on potentially unfavorable

terms with the second entity Conveys to that second entity a contractual right either:

To receive cash or another financial instrument from the first entity To exchange other financial instruments on potentially favorable terms

with the first entity

This recursive definition requires a chain of contractual obligations that ends with the delivery of cash or ownership interest in an entity

Financial Instruments – This Project Financial Instruments with Characteristics of Equity – separate

project Share Based Payments – existing, separate guidance Leases – separate project Investments in Affiliates – existing, separate guidance Benefits Liabilities – existing, separate guidance

Pensions Other Post-retirement OPEB Compensated Absences

Insurance Contracts – separate project Fair Value – Recognition, Measurement, Disclosures, to the extent

applicable to financial instruments – related separate project FASB [only] Project: Disclosures about Credit Quality [Finance

Receivables] and Allowance for Credit Losses

Loans Securities

Common stock, preferred stock, debt instruments

Mutual fund shares Investment entities other than mutual funds

Puts, Calls, Forward Contracts, etc. Derivative Contracts Hedging Agreements Credit Default Swaps

Joint Boards Documents Reducing Complexity Discussion Paper, and related Comment

Letters and Comment Letter Summary Comparison of FASB and IASB models (as of November 2009)

FASB Documents Accounting for Hedging Activities Exposure Draft, and related

Hedging Activities Comment Letters and Comment Letter Summary

Tentative decisions on March 31, regarding impairments, disclosures

IASB Documents IFRS 9: Financial Instruments – dealing with classification and

measurement – issued November 12, 2009 Exposure Draft, Amortised Cost and Impairment, issued

November 5, 2009 with a comment period ending June 30, 2010

FASB MODEL IASB MODEL

All financial assets and financial liabilities except: Leases Employers’ and plans’

obligations for pension, OPEB, compensated absences

Insurance contracts Equity investments in

consolidated subsidiaries Interest in consolidated VIEs Bifurcated, hybrid

instruments

Financial assets within the scope of IAS 39


Fair Value

Amortized Cost

Fair Value

Amortised Cost


Fair Value through Net Income (FV-NI)

Fair value through other comprehensive income

Amortized cost Default Classification

All instruments measured at fair value with changes in fair value recognized in net income

Certain changes permitted in OCI

Fair Value through Net Income (FV-NI)

Fair value through other comprehensive income (FV-OCI) (limited option)

Amortised cost Default Classification -

none


Debt instruments with principal amounts if the entity plans to hold to collect cash flow rather than sell or settle the instrument with a third party

Irrevocable election at initial recognition for equity instruments that are not held for trading


An option for certain types of the entity’s own debt

Must meet the FV-OCI classification criteria and measuring the debt at fair value results in a measurement attribute mismatch

A financial asset must be carried at amortised cost if: The objective of the

entity’s business model is to hold the asset to collect contractual cash flows; and

The asset’s contractual cash flows represent payment of principal and interest (“basic loan features”)


To be determined Irrevocable election at initial recognition if measuring at fair value eliminates or significantly reduces a measurement or recognition inconsistency (accounting mismatch)


For FV-OCI instruments, an entity required to determine if credit losses exist at the end of each reporting period

Credit impairment loss measure as the present value of management’s current estimate of cash flows not expected to be collected. Future scenarios not considered

Recognize current period credit impairments in net income; cumulative credit losses a separate balance sheet line

Amortised cost assets required to evaluate credit losses at the end of each reporting period

Impairment measured using an expected loss approach that incorporates expectations about future losses over the life of the financial assets

The effective interest rate used to estimated future cash flows is adjusted by deducting a margin for future credit losses expected on initial recognition


Recognized in net income for all financial instruments

Recognized in net income for all financial instruments except FV-OCI instruments for which gains and losses are recognized in OCI with no recycling


Not permitted Required if the entity’s business model for managing its financial assets changes


Receivables and payables arising in the normal course of business due in customary terms not exceeding approximately one year, if held for the collection or payment of contractual cash flows should be measured at carrying value. Receivables subject to impairment model [March 3]. Not-for-profit pledge related items excluded from the scope of the proposed standard.


Equity method required if entity has significant influence over the investee and the investment is considered related to the investor’s consolidated business. Fair value prohibited for these investments

Other investee securities measured at fair value with changes in earnings.


Initially and subsequently measured at the present value of the average core deposit liability amount discounted at the rate differential between the alternative funds rate and the all-in-cost-to-service rate over the implied maturity

Recognize the change in value, excluding current period interest accruals, in OCI

Realized gains and losses from settlements reflected in net income

Continue to be recorded at an amount no less than the amount payable on demand

Interests in subsidiaries, associates, or joint ventures accounted for under other standards

Employers’ rights and obligations under employee benefit plans

Insurance contracts accounted for under other standards

Share based payment awards accounted for under IFRS 2 [Share-based Payment] and ASC Topic 718 [compensation – Stock Compensation]

Instruments classified as equity in their entirety Perpetual instruments – common, preferred/preference Preferred shares required to be converted into a specified

number of common shares on a specified date or on the occurrence of an event certain to occur

Mandatorily redeemable and puttable instruments that either Require , or permit the holder to require, redemption to allow an

an existing group of shareholders, partners, or other participants to maintain control when one of them chooses to withdraw

Provide that the holder must own the instrument to engage in transactions with the entity or otherwise participate in entity activities, and the instrument’s terms require, or permit the holder or issuer to require, redemption when the holder ceases to engage in transactions or otherwise participate

Instruments classified as equity in their entirety – continued Contracts that require or may require an entity to issue a specified

number of its own perpetual equity instrument in exchange for a specified price [call options, forward contracts to issue shares, rights issues, and purchase warrants]

Instruments that require an entity to issue a specified number of its own perpetual shares for no further compensation [prepaid forward contact]

A contract that requires an entity to issue for a specified price, or no future consideration, a specified number of mandatorily redeemable or puttable instruments that will be equity in their entirety when issued

A contract that requires an entity to issue for a specified price, or no future consideration, a specified number of derivatives that will require the entity to issue a specified number of instruments that will be equity in their entirety when issued.

Bifurcated Instruments The portion of convertible debt instruments represented by the option

of the holder to convert into a specified number of instruments that will be equity in their entirety when issued should be classified as equity

Puttable shares that are not classified as equity in their entirety should be separated into liability and equity

Classified as liabilities [or assets] Contracts that require an entity to repurchase its own shares on a

specified date or on the occurrence of an event that is certain to occur should be separated into a liability for the amount to be paid and an offsetting debit to equity

Preferred shares convertible into a variable number of common shares at the holders’ option [usually equity under current US GAAP]

A freestanding written put option should be presented net as a liability in its entirety

The portion of convertible debt not classified as equity All other mandatorily redeemable instruments

Multiple deliverables in Revenue Recognition

Allocation of (separate the) purchase price to multiple component deliverables

Hybrid Instruments in Financial Instruments

Bifurcation – separate the accounting for debt and for equity elements

Objective Provide comprehensive guidance for

consolidation of all entities, including entities controlled by voting or similar interests.

Definition of control A reporting entity controls another entity

when the reporting entity has the power to direct the activities of that other entity to generate returns for the reporting entity.

Control though voting rights A reporting entity that holds more than half of the voting rights

in an entity meets the power element of the control definition, in the absence of other arrangements or circumstances

Control Otherwise A reporting entity with less that half of the voting rights in an

entity that has the legal or contractual ability to direct those activities meets the power element of the control definition

Options and convertible instruments A reporting entity should assess all the facts and circumstances

associated with options or convertible instruments when assessing whether it has the power through voting rights to direct the activities of an entity that significantly affect the returns

Agency relationships (including kick-out rights) No decisions have yet been reached Principal vs. agent

The IASB Exposure Draft issued in December, 2008 introduced the concept of a “Structured Entity”, similar to a VIE discussed in US GAAP and to Special Purpose entities

The overriding goal is to ensure that fair value has the same meaning in U.S. GAAP and IFRS

Establish how to calculate fair value, not when Key documents

FASB Statement 157 [issued 2006], now ASC Topic 820 ISAB Exposure Draft, issued May, 2009 which is

largely consistent with U.S. GAAP, including the fair value input hierarchy [3 level]

Initial Measurement Fair value at initial recognition Recognition of day one gains or losses

Subsequent Measurement Fair value defined as an exit price The Principal (or Most Advantageous) Market Market Participants Application to Assets – consider highest and best use [“in use”

valuation premise] for nonfinancial assets only; not applicable to liabilities or financial assets

Financial Assets in a Market That Is Not Active Application to Liabilities The Asset or Liability subject to the standard Valuation Techniques Level 2 Inputs

Occasions when the transaction price may not be fair value when: The transaction is between related parties The transaction takes place under duress, or the

seller is forced to accept the transaction price The transaction unit of account differs from the unit

of account for the asset or liability measured at fair value

The transaction occurs in a different market from the market in which the entity would sell or transfer the instrument

Recognition of day one gains or losses will be discussed at a future meeting

Market bases, and reflects the assumptions market participants would use to price the instrument

Market participants are assumed to have a reasonable understanding about the instrument and the transaction

Market participants are not related parties A related party transaction price may be used as an

input if the transaction was at market terms Unobservable inputs from the entity’s own data,

adjusted for reasonably available information considered by market participants, are considered market participant assumptions and meet the objective of a fair value measurement

General valuation considerations Price

Quoted price of an identical liability instrument when traded as an asset Quoted price for similar liability instruments when traded as an asset An income approach [present value], or market approach [an “entrance

price” for a new identical instrument]

Market participant transferee has the knowledge and the ability to fulfill an identical obligation

Nonperformance risk Included in the determination of fair value Will clarify what, in addition to credit risk, comprises

nonperformance risk Restrictions on the transfer of a liability - no

additional adjustment if considered in other inputs

An entity must display total comprehensive income in a continuous statement of comprehensive income

A continuous display of comprehensive income must display two sections – profit and loss or net income, and comprehensive income

The components of each section must be reported consistently

Affirms the existing option to present each component net of related income taxes, or before income taxes with a section for aggregated income tax effects presented separately

Affirmed the income tax effect related to each component of comprehensive income may be displayed on the face of the statement, or in the notes to the financial statements

Decided not to change guidance regarding items required to be presented contained in other standards

The FASB affirmed that reclassification between OCI and net income should be reported in the same level of detail as originally reported

The IASB affirmed that the components of OCI that are not reclassified upon derecognition should be presented together, and the components that reclassified upon derecognition should be presented together

Exposure drafts issued by the two boards on September 25, 2008 FASB: Amending the Criteria for Reporting a

Discontinued Operation IASB: Discontinued Operations

Existing literature FASB ASC Topic 205-20: Presentation –

Discontinued Operations IFRS 5, Non-current Assets Held for Sale and

Discontinued Operations

Scope The FASB decided to eliminate the existing scope exceptions to

Subtopic 205-20 [identified in 360-10-15-5] which include certain intangibles, equity method financial instruments, deferred tax assets, and others

Definition of a discontinued operation: a component that has been disposed, or classified as held-for-sale, and Represents a separate major line of business or geographical area

of operations Is part of a single plan of disposal Is a business that meets the criteria to be classified as held for sale

on acquisition

Presentation – presented in a separate section on the face of an entity’s financial statements

Disposal of a component of an entity that meets the definition of a discontinued operation

Profit or loss, plus major income and expense items, including impairments, depreciation, interest, and amortization

The major classes of cash flow (operating, investing, and financing) Reconciliation of the major classes of assets and liabilities classified as held for sale

in the notes to total assets and liabilities classified as held for sale presented separately on the face of the statement of financial position

A reconciliation of the profit and loss presented in the notes to the after-tax profit or loss from discontinued operations in the statement of comprehensive income

Disposal of a component of an entity that does not meet the definition of a discontinued operation

A somewhat reduced version of the disclosures for disposals that meet the definition

Disposals of long-lived assets that are not components of an entity Amounts not separately in the statements of financial position, or a reconciliation

Continuing involvement and continuing cash flows The nature of the continuing activities; the expected period of continued

involvement; the amount of the continuing cash flows; amounts in continuing operations after disposal that had previously been eliminated as intra-entity transactions

Scope - Applicable to all insurance contracts, not just insurance companies Recognition Measurement

Measurement Objective Risk Adjustment [IASB, separate; FASB, included in the composite residual margin] Non-performance by the Insurer Day 1 Differences Unbundling Deposit Floor Policyholder Behavior Participating Features [IASB, include in measurement; FASB recognize a liability] Residual margin [expected premiums less expected claims and a risk adjustment]

determined at inception reflected on basis of time, or expected benefits and claims if different from ratable over time

Derecognition Reinsurance Acquisition Costs – Expense when incurred, unlike US GAAP Presentation

The measurement should assess the customer contract considering the elements below to measure the combination of rights and obligations arising from an insurance contract, which should be updated each reporting period:

The unbiased, probability-weighted average of future cash flows expected to arise as the insurer fulfills the obligation

Incorporation of the time value of money A risk adjustment for the effects of uncertainty about the amount and

timing of future cash flows, including the uncertainty that arises from having to fulfill the net obligation arising from the insurance contract

An amount that eliminates any gain at inception of the contract A component of the contract that is not interdependent with other contract

components should be unbundled A deposit floor should not be used, although policyholder withdrawals would

be including in estimating the expected contractual cash flows

The reinsurer: Use the same recognition and measurement approach for the reinsurance contracts is

issues as all other insurers use for the insurance contract they have issued Should charge the income statement ceding commissions for proportional reinsurance

contracts in a manner consistent with the treatment of acquisition costs

The cedent [entity reinsuring its contract obligations]: Recognize and measure its reinsurance asset using the same recognition and

measurement approach it uses for the reinsured portion of the underlying insurance contracts is has issued

Should not derecognize the related direct insurance liabilities unless the obligation specified in the insurance contract is (legally) discharged, cancelled, or expired

Should not offset reinsurance balances against related direct reinsurance balances (balance sheet and income statement) unless legal requirements for offsetting are met

Should credit to the income statement ceding commissions for proportional reinsurance contracts in a manner consistent with the treatment of acquisition costs

Diverged Financial Instruments

Semi – converged Fair Value Measurements OCI recycling

Converged Leases Revenue Recognition Consolidation Financial Statement Presentation Statement of Comprehensive Income – except OCI recycling Financial Instruments With Characteristics of Equity Discontinued Operations Insurance Contracts

Contingencies – Exposure Draft, Measuring Liabilities in IAS 37, Issued January 2010 Recognition threshold – existence of obligation Measurement – probability weighted

Post-employment Benefits FASB has focused on disclosures recently, IASB on

recognition Treatment of actuarial gains and losses, including

“recycling” of this OCI item IASB deliberations regarding “assumed rate of

return on plan assets”

www.fasb.org www.iasb.org Setting the Standard on

www.cfodirect.pwc.com www.iasplus.com www.KPMGInstitutes.com See “Issues” on www.ey.com

Bp April 12 2010 Presentation Accounting Principles Under Development What Is Convergincg On You...

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