[CCWG-ACCT] Third Draft Proposal -- substantive Comments/Edits

[Rosemary E. Fei]

Dear CCWG:

To confirm our comprehension of the CCWG’s decisions on the many changes from the Second to the Third Proposal, we reviewed the Third Proposal as published.  In doing so, we noted points where the language in the Third Proposal does not unambiguously reflect our current substantive understanding of the CCWG’s intent.  In our comments on the Third Proposal draft, we suggested edits on many of these points which were not accepted, so perhaps we have misunderstood the intent.  As to other points, we don’t have a clear understanding of the CCWG’s intent.  In either case, we would like clarification.

In the attached table you will find our joint substantive comments on the Third Proposal as published.  As we approach the implementation stage, we would welcome an opportunity to discuss any of our comments that raise questions or concerns, to ensure we know what we’re asked to implement.  We also hope these comments may be useful to clarify the final proposal for the general reader.

To make the volume of our comments more manageable, we are sending staff separately our comments on the Third Proposal that raise only non-substantive issues.

Holly and Rosemary

Rosemary E. Fei
Adler & Colvin
235 Montgomery Street, Suite 1220
San Francisco, CA 94104
415/421-7555 (phone)
415/421-0712 (fax)
rfei at adlercolvin.com
www.adlercolvin.com



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