October 29, 2010


VIA ELECTRONIC MAIL 


Russell G. Golden
Technical Director
File Reference No. 1820-100
Financial Accounting Standards Board
401 Merritt 7
PO Box 5116
Norwalk, CT 06856-5116
Electronic Address: director@fasb.org


Re: Revenue Recognition (Topic 605), Revenue from Contracts with Customers

Dear Mr. Golden:

The Office of Advocacy (Advocacy) is submitting this comment in response to the Financial 
Accounting Standards Board (FASB) Exposure Draft of a proposed Accounting Standards Update of 
Topic 605, File Reference No. 1820-100.  Advocacy is concerned that the Exposure Draft would have 
negative consequences for small businesses.

Advocacy was established pursuant to P.L. 94-305 to represent the views of small business before 
Federal agencies and Congress.(1)  Advocacy is an independent office within SBA, so the views 
expressed by Advocacy do not necessarily reflect the views of the SBA or the Administration.  

On October 20, 2010, Advocacy staff participated in a conference call with FASB staff responsible 
for drafting the Exposure Draft.  During the call, Advocacy conveyed to FASB staff the various 
concerns of small businesses that the Exposure Draft, if finalized, would negatively impact small 
businesses. FASB assured Advocacy that the process to finalize the Exposure Draft would be open 
and transparent to the public, and that FASB would take into account the concerns of small businesses 
during this process.  Advocacy commends FASB for participating in the conference call.  Advocacy 
looks forward to working with FASB during this process to minimize the burdens of Exposure Draft 
on small businesses.  

We appreciate FASB staff taking the time to talk with Advocacy to discuss the concerns of small 
business regarding the Exposure Draft.  If you have any questions or require additional information 
please contact Assistant Chief Counsel for Dillon Taylor at (202) 401-9787 or by email at 
Dillon.Taylor@sba.gov.  

Sincerely,

/s/
					
Winslow Sargeant, Ph.D. 
Chief Counsel for Advocacy

ENDNOTES

1.  5 U.S.C. § 634a (1976). http://www.sba.gov/advo/laws/law_sta.html#634a.


					
































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