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For prior year communications, please see the Advocacy Archives

Letter dated 12/01/10 - Financial Accounting Standards Board [html], [text] or [PDF File] - Proposed Accounting Standards Update regarding Leases (Topic 840) ;  (File Reference No. 1850-100; August 17;   Fact Sheet Summarizing Advocacy's Letter

Letter dated 10/29/10 - Financial Accounting Standards Board [html], [text] or [PDF File] - Proposed Accounting Standards Update regarding Revenue from Contracts with Customers ;  (File Reference No. 1820-100; June 24, 2010). Fact Sheet Summarizing Advocacy's Letter.

Response letter dated 10/21/10 - The Honorable Olympia J. Snowe, Ranking Member, U.S. Senate Committee on Small Business and Entrepreneurship [html], [text] or [PDF File] - Regarding Expanded Form 1099 Filing Requirements

Letter dated 05/20/10 - Department of Labor, Employee Benefits Security Administration [html], [text] or [PDF File] - Commending the Employee Benefits Security Administration (EBSA) for taking into account the concerns of the small business community in its announcement regarding new e-Signature Option for Forms 5500;  (Release Number: 10-680-NAT; May 13 2010).

Letter dated 12/23/09 - Federal Reserve System [html], [text] or [PDF File] - Truth in Lending; Proposed Rule; 74 Fed. Reg. 43231, August 26, 2009; [PDF File] or [text];   Fact Sheet Summarizing Advocacy's Letter

Letter dated 09/29/09 - Tax Reform Subcommittee, Presidential Economic Recovery Advisory Board [html], [text] or [PDF File] - Recommendations for Tax Reform;  Fact Sheet Summarizing Advocacy's Letter

Letter dated 07/09/09 - Comptroller of the Currency, Federal Reserve System, Federal Deposit Insurance Corporation, Office of Thrift Supervision, Farm Credit Administration, National Credit Union Administration [html], [text] or [PDF File] - Registration of Mortgage Loan Originators; Proposed Rule; 74 Fed. Reg. 27385 June 9, 2009  [PDF File] or [text]; Fact Sheet Summarizing Advocacy's Letter.

Letter dated 06/30/09 - Financial Accounting Standards Board (FASB) and International Accounting Standards Board (IASB) [html], [text] or [PDF File] - Lease Accounting Standards: Financial Accounting Series Discussion Paper (FASB) (March 19, 2009)  [PDF File] and Discussion Paper, Leases Preliminary Views (IASB) (March 2009) [PDF File];  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 06/30/08 - Securities and Exchange Commission [html], [text] or [PDF File] - regarding the Commission’s plans to unify America’s current generally accepted accounting principles (GAAP) with the International Financial Reporting Standards (IFRS);  Fact Sheet Summarizing Advocacy's Letter

Letter dated 06/25/08 - Securities and Exchange Commission [html], [text] or [PDF File] - strongly supporting the Securities and Exchange Commission’s (SEC’s) approval of a one-year extension of Section 404(b) of the Sarbanes-Oxley Act of 2002 for smaller public companies;  Fact Sheet Summarizing Advocacy's Letter

Letter dated 04/24/08 - Department of Treasury, Internal Revenue Service [html], [text] or [PDF File] - Government entities required to withhold 3% on payments for services and property; IRS Notice 2008-38 [PDF File] ;  Fact Sheet Summarizing Advocacy's Letter

Letter dated 04/08/08 - Federal Reserve System [html], [text] or [PDF File] - Truth in Lending; Proposed Rule; 73 Fed. Reg. 1671, January 9, 2008; [PDF File] or [text];   Fact Sheet Summarizing Advocacy's Letter

Letter dated 03/21/08 - Department of Treasury, Internal Revenue Service [html], [text] or [PDF File] - Guidance Regarding Marketing of Refund Anticipation Loans (RALs) and Certain Other Products in Connection With the Preparation of a Tax Return; 73 Fed. Reg. 1131, January 7, 2008 ; [PDF File] or [text];  Fact Sheet Summarizing Advocacy's Letter

Letter dated 10/02/07 - Securities and Exchange Commission [html], [text] or [PDF File] - Alternative proposals on shareholder proxy access, Shareholder Proposals Relating to the Election of Directors (“Short Proposal”); 72 Fed. Reg. 43488 (August 3, 2007).  [PDF File] or [text] and Shareholder Proposals (“Long Proposal”); 72 Fed. Reg. 43465 (August 3, 2007).  [PDF File] or [text].  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 06/27/07 - Securities and Exchange Commission [html] or [PDF File] - Notice of Filing of Proposed Rule Change Amending FAST and DRS Limited Requirements for Transfer Agents; 72 Fed. Reg. 30648 (June 1, 2007).  [PDF File] or [text].  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 05/25/07 - Securities and Exchange Commission, [text] or [PDF File] - SEC open Meeting on Section 404 of the Sarbanes-Oxley Act, May 23, 2007

Letter dated 05/10/07 - Department of Treasury and Internal Revenue Service [html], [text] or [PDF File] - commending them for their recent revised Initial Regulatory Flexibility Analysis (IRFA) for the proposed rule entitled “Escrow Accounts, Trusts, and Other Funds Used During Deferred Exchanges of Like-Kind Property.” 72 Fed. Reg. 13055, March 20, 2007; [PDF File] or [text]

Letter dated 03/23/07 - Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau [html], [text] or [PDF File] - Comments on their Notice of Proposed Rulemaking on Tax Classification of Cigars and Cigarettes; 71 Fed. Reg. 62505 (October 25, 2006).  [PDF File] or [text].  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 02/21/07 - Securities and Exchange Commission & Public Company Accounting Oversight Board [html], [text] or [PDF File] - Management’s Report on Internal Control Over Financial Reporting; Proposed interpretation; Proposed Rule; 71 Fed. Reg. 77635 (December 27, 2006).  [PDF File] or [text].  Proposed Auditing Standard-An Audit of Internal Control Over Financial Reporting that is Integrated with an Audit of Financial Statements and Related Proposals; Release No. 2006-007 (Public Company Accounting Oversight Board, Dec. 2006).  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 06/09/06 - Internal Revenue Service [html], [text] or [PDF File] - Income Attributable to Domestic Production; 71 Fed. Reg. 31268 (June 1, 2006).  [PDF File] or [text].

Letter dated 05/08/06 – Department of Treasury and Internal Revenue Service [PDF File] or [text] - Comments in response to their notice of proposed rulemaking entitled, Escrow Accounts, Trusts and Other Funds Used During Exchanges of Like-Kind Property; 71 Fed. Reg. 6231 February 7, 2006.  [PDF File] or [text]  Fact Sheet Summarizing Advocacy's Letter.

Statement dated 05/03/06 - House Committee on Government Reform [PDF File] or [text] - Regarding the problems small public companies face with new Sarbanes Oxley Act rules.

Letter dated 04/27/06 - Securities and Exchange Commission [PDF File] or [text] - Regarding compliance experience with section 404 of the Sarbanes Oxley Act of 2002;  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 01/26/06 - Securities and Exchange Commission’s Advisory Committee [html], [text] or [PDF File] - Smaller Public Companies that strongly supported draft recommendations to reform securities regulation.

Letter dated 01/03/06 - Department of Treasury, Internal Revenue Service [html], [text] or [PDF File] - Comments on proposed regulations for the Income Attributable to Domestic Production Activities; 70 Fed. Reg. 67220, November 4, 2005  [PDF File] or [text]  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 10/14/05 - Department of Labor, Employee Benefits Security Administration [html] or [PDF File] - Regarding Notice of Proposed Rulemaking Form 5500 E-Filing Regulation; 70 Fed. Reg. 51,542; (August 30, 2005) [PDF File] or [text] . Fact Sheet Summarizing Advocacy's Letter [PDF File].

Letter dated 10/03/05 - Securities and Exchange Commission [html] or [PDF File] - Regarding extension of compliance dates for Management’s Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports of Companies That Are Not Accelerated Filers; 70 Fed. Reg. 56,825; (September 29, 2005) [PDF File] or [text] . Fact Sheet Summarizing Advocacy's Letter [PDF File].

Letter dated 03/11/05 - Securities and Exchange Commission [PDF File] - regarding extension of compliance dates for the final rule, Management’s Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports of Non- Accelerated Filers and Foreign Private Issuers; 70 Fed. Reg. 11528, March 8, 2005).  [PDF File] or [text].  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 04/15/04 - OCC, FRS, FDIC and OTS [html], [text] or [PDF File] - Request for Burden Reduction Recommendations; Consumer Protection; Lending Related Rules; Economic Growth and Regulatory Paperwork Reduction Act of 1996 Review; 69 Fed. Reg. 5729 (January 21, 2004) [PDF File] or [text] . Fact Sheet Summarizing Advocacy's Letter [PDF File]

Letter dated 04/06/04 - OCC, FRS, FDIC and OTS [html], [text] or [PDF File] - Joint proposed rule to amend the Community Reinvestment Act (CRA) regulations; 69 Fed. Reg. 5729 (February 6, 2004) [PDF File] or [text] . Fact Sheet Summarizing Advocacy's Letter [PDF File]

Letter dated 03/12/04 - Federal Reserve System [html], [text] or [PDF File] - Regarding the notice of proposed rulemaking on the Availability of Funds and Collection of Checks; 69 Fed. Reg. 1470 (January 8, 2004) [PDF File] or [text] . Fact Sheet Summarizing Advocacy's Letter [PDF File]

Letter dated 12/18/03 - Securities and Exchange Commission [html], [text], or [PDF File] - Proposed Rule, Security Holder Director Nominations; 68 Fed. Reg. 60784 (Oct. 23, 2003) [PDF File]:  Fact Sheet Summarizing Advocacy's Letter.

Letter dated 10/06/03 - Internal Revenue Service  [html], [text], or [PDF File] -  Regarding the notice of proposed rulemaking; Depreciation of Vans and Light Trucks; 68 Fed. Reg. 40224, (July 7, 2003)  [PDf File] or [text].  Fact Sheet Summarizing Advocacy's Letter [PDF File].

Letter dated 09/09/03 - Internal Revenue Service [html], [text], or [PDF File] - To Assistant Deputy Commissioner David A. Mador supplementing previous comments submitted by the Office of Advocacy in regard to Excise Taxes: Communications Services, Distance Sensitivity. 58 Fed. Reg.15,690 (Apr. 1, 2003) [PDF File] Fact Sheet Summarizing Advocacy's Letter.
Letter dated 03/07/03 - U.S. Department of Treasury [html], [text], or [PDF File] - To Assistant Secretary Pamela Olson in appreciation of Treasury's action in postponing final action on Excise Taxes: Definition of Highway Vehicle.

Letter dated 07/07/03 - U.S. Department of Treasury [html], [text] or [PDF File] - Regarding the notice of proposed rulemaking on the Financial Crimes Enforcement Network; Anti-Money Laundering Programs for Investment Advisers; 68 Fed. Reg. 23646 (May 5, 2003) [PDF File] or [text].

Testimony dated 02/27/03 - Internal Revenue Service [html], [text], or [PDF File] - Russell Orban, Assistant Chief Counsel for Tax Policy of the Office of Advocacy, testified before the Internal Revenue Service on the proposed rule, Excise Taxes; Definition of Highway Vehicle.

Letter dated 01/13/03 - Securities and Exchange Commission [html], [text], or [PDF File] -  Regarding the notice of proposed rulemaking; Strengthening the Commission's Requirements Regarding Auditor Independence ; 67 Fed. Reg. 76,780 (December 13, 2002)  [PDf File] or [text]. 

Testimony dated 12/05/02 - Internal Revenue Service [PDF File], or [text], - Russell Orban, Assistant Chief Counsel for Tax Policy of the Office of Advocacy, testified before the Internal Revenue Service on the proposed rule, Guidance on Reporting of Deposit Interest Paid to Nonresident Aliens

Letter dated 12/04/02 - Internal Revenue Service [html], [text], or [PDF File] -  Regarding the notice of proposed rulemaking; Excise Taxes; Definition of Highway Vehicle;  67 Fed. Reg. 38,913 (June 6, 2002)  [PDf File] or [text]. 

Letter dated 11/14/02 - Internal Revenue Service [html], [text] or [PDF File] - Regarding Guidance on Reporting of Deposit Interest paid to Nonresident Aliens; 67 Fed. Reg. 50386 (August 2, 2002) [PDF File] or [text].

Letter dated 08/26/02 - National Credit Union Administration [html], [text], or [PDF File] - Regarding Size Standard for Small Credit Unions;  67 Fed. Reg. 38431 (June 4, 2002) [PDF File] or [text]

Letter dated 08/19/02 - Securities and Exchange Commission [html], [text], or [PDF File] - Certification of Disclosure in Companies' Quarterly and Annual Reports Rule;  67 Fed. Reg. 41877 (June 20, 2002) [PDF File] or [text]

Letter dated 08/13/02 - Internal Revenue Service [html], [text], or [PDF File] -Request for a 90-day extension to file comments on the Notice of Proposed Rulemaking: Excise Taxes; Definition of Highway Vehicle;  67 Fed. Reg. 38,913 (June 6, 2002) [PDF File] or [text]

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