Scenario A The client has indicated in their memo that the debt securities which have declined in fair value are not other-than-temporarily impaired and therefore the client does not intend to record an impairment loss in earnings. They have provided some applicable facts which support this decision and which are in accordance with the requirements outlined in the Codification: They did not intend to sell the debt securities. Under ASC 320-10-35-33A, the intent to sell a debt security automatically creates an other-than-temporary impairment. They determined that they would not likely be required to sell the securities before recovery of their amortized cost bases. This is the second requirement provided in section ASC 320-10-35-33B. The client also has indicated that they fully expect to recover the amortized cost bases of the securities because there is no evidence that the debtor will not continue to make payments as scheduled. The Codification does indicate that such an assessment should be made, however ASC 320-10-35-33F through 33I quite clearly indicate that there are numerous factors to be considered when determining if the security can be recovered. The client did not effectively communicate that they had considered multiple factors, other than the fact that the payments have continued to be made as scheduled. Furthermore, I am concerned that although as of the balance sheet date the client did not intend to sell the securities, within a month that decision had changed. I feel that despite the written documentation they provided the auditors as of March 31 st , the sale of these debt securities should still be taken into consideration. I suggest that the appropriate accounting for these securities as of the March 31, 2010 balance sheet date is that they be treated as other-than-temporarily impaired and as such, a write-down accounted for as a realized loss should be recorded (SEC Staff Accounting Bulletin No. 59). This decision is based on ASC 320-10-35-33F which indicates under item a. that a factor to be considered is the length of time and the extent to which the fair value has been less than the amortized cost basis. The client has indicated to us the Municipal bonds and Corporate bonds have been impaired for 18 months and 32 months respectively. This time more than exceeds the fiscal year for which we are reporting, indicating that the impairment is other-than temporary. Furthermore, item g. of that same section of the codification suggests that we consider transactions or further declines in fair value after the balance sheet date. Although the client did not indicate the fair value had declined further, we do know that the debt securities were sold, indicating again that they better qualify as other-than-temporarily impaired securities. If the fair value of the debt securities declined below historical cost by only 2 percent, I would take that information into consideration because ASC 320-10-35-33F item number c. does point out that a factor to consider is the historical and implied volatility of the fair value of the security. However, AU Section 332.47 clearly states that judgment is required in determining whether factors exist that indicate that an impairment loss has been incurred at the end of the reporting period. These judgments are based on subjective as well as objective factors, including knowledge and experience about past and current events and assumptions about future events (AU Section 332.47, p 1933). Based on this responsibility and all information and assumptions provided, I would still recommend that the client write-down the impaired debt securities. Scenario B The client, Company X, provided a thorough evaluation of the decline in fair value for the securities they owned which were classified as available-for-sale. Their evaluation appears from my standpoint to be in accordance with what is suggested in the Staff Accounting Bulletin Topic 5.M which states that management should consider all available evidence to evaluate the realizable value of its investment in equity securities classified as available-for-sale (ASC 320- 10-S99). The same bulletin provides the following factors to consider when determining if the securities are other than temporary and if a write-down of the carrying value is required: a. The length of the time and the extent to which the market value has been less than cost; b. The financial condition and near-term prospects of the issuer, including any specific events which may influence the operations of the issuer such as changes in technology that may impair the earnings potential of the investment or the discontinuance of a segment of the business that may affect the future earnings potential; or c. The intent and ability of the holder to retain its investment in the issuer for a period of time sufficient to allow for any anticipated recovery in market value (ASC 320-10- S99). Based on the information provided by Company X, it is apparent that the length of the impairment has been less than one year, and even within that year, the fair value has begun to rise from $80 per share to $85 per share. Furthermore, Company X analyzed and prepared forecasts indicating that recovery could be expected by April 2011. From the information provided, it appears that they were not aware of the pending changes that were later announced by Company B. These factors indicate that in fact, Company Xs securities classified as available for sale are not other than temporary and do not need to be written down on the December 31, 2010 financial statements. However, I would note that if Company X had any indication as of December 31, 2010 that Company B would be making organizational changes, then it would then be necessary for them to report the securities which were classified as available for sale as other than temporary and respectively write them down on the balance sheets of the company.