Includes “I strongly disagree with the Board’s proposed concepts statement, primarily because it continues to exclude – in fund financial reporting – significant long-term liabilities arising from pension and OPEB transactions and events. … 1) Shorter-Term Perspective Produces Significantly Incomplete, Non-Comparable Results … 2. Proposal Has Misleading Language Re: Accrual Accounting and Interperiod Equity … In my opinion, the Board has attempted to rationalize a model that cannot be rationalized.”
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