CBF Comment Letter: Updates 2016-200 and 2016-210

Re: File Reference 2016-200: Proposed ASU Compensation—Retirement Benefits (Topic 715). Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost and;
File Reference 2016-210: Proposed ASU Compensation—Retirement Benefits—Defined Benefit Plans—General (Subtopic 715-20). Changes to the Disclosure Requirements for Defined Benefit Plans

Dear Chairman Golden:
Financial Executives International (FEI) is a leading international organization of more than 10,000 members, including Chief Financial Officers, Controllers, Treasurers, Tax Executives and other senior-level financial executives. The Committee on Corporate Reporting (CCR) is a technical committee of FEI, which reviews and responds to research studies, statements, pronouncements, pending legislation, proposals and other documents issued by domestic and international agencies and organizations. The Committee on Benefits Finance (CBF) debates and develops recommendations on existing and proposed legislation and regulations affecting pension and incentive compensation plans, health and disability insurance, unemployment compensation and regulation and other areas. When deemed appropriate, CBF may communicate its positions to government agencies, legislators, industry regulators and standard setters, as well as professional and business organizations. CCR together with CBF represent approximately 5 trillion in market capitalization.

We appreciate the opportunity to provide our views on the proposed Updates 2016-200 and 2016-210.

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