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Property and Liability Insurance Companies — AICPA Audit and Accounting Guide

Publisher: AICPA
Availability: 12/14/2008
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Description

This Audit and Accounting Guide provides the latest information on accounting and auditing issues affecting the property and liability insurance industry. Updated with conforming changes as of May 1, 2008, it includes guidance in planning and performing audits under the risk assessment standards (SAS Nos. 104-111). This edition of the guide has also been conformed to reflect the Defining Professional Requirements standards (SAS No. 102 and SSAE No. 13). Furthermore, it provides additional guidance on the auditor's responsibilities as set forth in SAS Nos. 112-114, including identifying and reporting internal control deficiencies, understanding the link between the auditor's consideration of fraud and the auditor's assessment of risk, dating of the management representation letter, and the auditor's communications with those charged with governance.

The guide summarizes applicable requirements and practices, and delivers "how-to" advice for handling audit and accounting issues common to the property and liability insurance industry. It includes accounting requirements for the National Association of Insurance Commissioners (NAIC) Statements of Statutory Accounting Principles (SSAP) and a discussion of the relevant financial statement considerations for the property and liability insurance industry. The guide covers the following new pronouncements:

  • Introduction to FASB Statement No. 160, Noncontrolling Interests in Consolidated Financial Statements - an amendment of ARB No. 51
  • Expanded discussion of FASB Statement No. 157, Fair Value Measurements, including the related FASB Staff Positions issued, and FASB Statement No. 159, Fair Value Option for Financial Assets and Financial Liabilities--Including an amendment of FASB Statement No. 115
  • Discussion of key audit requirements of PCAOB Auditing Standard No. 5, An Audit of Internal Control Over Financial Reporting That is Integrated with an Audit of Financial Statements
  • NAIC Statements of Statutory Accounting Principles through No. 97 Investments in Subsidiary, Controlled, and Affiliated Entities, A Replacement of SSAP No. 88

For a topical listing of subject matter by chapter, click on the Table of Contents tab.

Table of Contents

  • Chapter 1 - Nature, Conduct, and Regulation of the Business
    • General Nature of the Business
    • Kinds of Insurance
    • Organizations
      • Methods of Producing Business
    • Major Transaction Cycles
      • Underwriting of Risks
      • Processing and Payment of Claims
      • Investments
    • Accounting Practices
      • State Insurance Regulation
      • National Association of Insurance Commissioners
      • Federal Regulation—Securities and Exchange Commission
      • Federal Regulation—Terrorism
      • Industry Associations
      • Statutory Accounting Practices
      • Permitted Statutory Accounting Practices
      • Generally Accepted Accounting Principles
      • Comparison of Generally Accepted Accounting Principles and Statutory Accounting Practices
  • Chapter 2 -Audit Considerations
    • Introduction
    • Scope of the Audit Engagement
      • General Considerations
      • PCAOB Integrated Audit of Financial Statements and Internal Control Over Financial Reporting
    • Planning and Other Auditing Considerations
      • Audit Planning
      • Audit Risk
      • Planning Materiality
    • Use of Assertions in Obtaining Audit Evidence
    • Understanding the Entity, Its Environment, and Its Internal Control
      • Risk Assessment Procedures
      • Discussion Among the Audit Team
      • Understanding of the Entity and Its Environment
      • Understanding of Internal Control
    • Use of Information Technology
    • Assessment of Risks of Material Misstatement and the Design of Further Audit Procedures
      • Assessing the Risks of Material Misstatement
      • Designing and Performing Further Audit Procedures
    • Evaluating Misstatements
    • Audit Documentation
      • Consideration of the Work of Internal Auditors
      • Communications by Successor Auditors
    • Communication of Matters Related to Internal Control
    • Communication With Audit Committees
    • Consideration of Fraud in a Financial Statement Audit
      • The Importance of Exercising Professional Skepticism
      • Discussion Among Engagement Personnel Regarding the Risks of Material Misstatement Due to Fraud
      • Insurance Industry Fraud Risk Factors
      • Obtaining the Information Needed to Identify the Risks of Material Misstatement Due to Fraud
      • Considering Fraud Risk Factors
      • Identifying Risks That May Result in a Material Misstatement Due to Fraud
      • Assessing the Identified Risks After Taking Into Account an Evaluation of the Entity's Programs and Controls That Address the Risks
      • Responding to the Results of the Assessment
      • Evaluating Audit Evidence
      • Responding to Misstatements That May Be the Result of Fraud
      • Communicating About Possible Fraud to Management, Those Charged With Governance, and Others
      • Documentation and Guidance
    • Auditing Fair Value Measurements and Disclosures
    • Letters for State Insurance Regulators to Comply With the NAIC Model Audit Rule
    • SEC Requirements for Management's Report on Internal Control Over Financial Reporting
    • Auditor's Consideration of State Regulatory Examinations
    • Auditor's Consideration of Permitted Statutory Accounting Practices
    • The Auditor's Consideration of Regulatory Risk-Based Capital for Property and Liability Insurance Enterprises
      • Introduction and Scope
      • Overview of Risk-Based Capital
      • Audit Planning
      • Going-Concern Considerations
    • Exhibits
  • Chapter 3 - The Premium Cycle
    • Rating
    • The Transaction Cycle
      • Evaluating and Accepting Risks
      • Issuing Policies
      • Billing and Collecting Premiums
      • Paying Commissions and Other Costs of Acquiring Business
      • Adjusting Premiums
      • Home Office and Branch Office Recordkeeping
    • Premiums Transaction Flow
    • Accounting Principles
      • Revenue Recognition
      • Policy Acquisition Costs
      • Premium Deficiencies
    • Accounting for Contracts That Do Not Transfer Insurance Risk
    • Special Risk Considerations
    • Accounting by Certain Entities (Including Entities With Trade Receivables) That Lend to or Finance the Activities of Others
  • Chapter 4 - The Loss Reserving and Claims Cycle
    • Accounting Practices
      • Statutory Accounting Practices
    • Types of Business and Their Effect on the Estimation Process
      • Policy Duration
      • Type of Coverage
      • Kind of Insurance Underwritten, Line of Business, or Type of Risk
    • The Transaction Cycle
      • Claim Acceptance and Processing
      • Claim Adjustment and Estimation
      • Claim Settlement
      • Reinsurance Receivable
      • Salvage and Subrogation
    • Claims Transaction Flow
    • Components of Loss Reserves
    • Estimating Methods
      • Illustrative Projection Data
    • Loss Adjustment Expense Reserves
      • DCC Reserve Calculation Approaches
      • AO Reserve Calculation Approaches
    • Changes in the Environment
    • Use of Specialists by Management in Determining Loss Reserves
    • Guaranty Fund and Other Assessments
    • Auditing Loss Reserves
      • Auditing the Claims Database
      • Evaluating the Reasonableness of the Estimate
      • Analytical Procedures
      • Loss Reserve Ranges
      • Evaluating the Reasonableness of Loss Adjustment Expense Reserves
      • Ceded Reinsurance Receivable
    • Disclosures of Certain Matters in the Financial Statements of Insurance Enterprises
      • Scope
      • Applicability to Statutory Financial Statements
      • Relationship to Other Pronouncements
      • Conclusions
      • Illustrative Disclosures
  • Chapter 5 - The Investment Cycle
    • Regulation
    • Investment Alternatives
      • Short-Term Investments
      • Other Investment Alternatives
    • The Transaction Cycle
      • Investment Evaluation
      • Safekeeping
      • Recordkeeping
    • FASB Statement Nos. 157 and 159
      • Definition of Fair Value
      • Valuation Techniques
      • Present Value Techniques
      • The Fair Value Hierarchy
      • Disclosures
      • Fair Value Option
    • Accounting Practices
      • Held-to-Maturity Securities
      • Trading Securities
      • Available-for-Sale Securities
      • Impairment of Securities
      • Accounting for Derivative Instruments and Hedging Activities
      • Statutory Accounting Practices
    • Special Risk Considerations
  • Chapter 6 - Reinsurance
    • Types of Reinsurance
    • Kinds of Reinsurance Contracts
      • Bases of Reinsurance Transactions
    • Accounting Practices
      • Reporting Assets and Liabilities
      • Reporting Revenues and Costs
      • Reinsurance Agreements Not Qualifying for Reinsurance Accounting Under FASB Statement No. 113 or EITF Issue No. 93-6
      • Disclosures
      • Statutory Accounting Practices
    • Special Risk Considerations
    • Internal Control of the Ceding Company
      • Control Environment
      • Control Activities
      • Information and Communications
    • Internal Control of the Assuming Company
    • Auditing Procedures for the Ceding Company
    • Auditing Procedures for the Assuming Company
    • Pools, Associations, and Syndicates
    • Reinsurance Intermediaries
    • Accounting for Foreign Property and Liability Reinsurance
      • Current Practices
      • Comparison With Practices in Other Industries
      • Disclosures
  • Chapter 7 - Taxes
    • Federal Income Taxation
      • Provisions of the Tax Reform Act of 1986 on Property and Liability Insurance Companies
      • Provisions of the Pension Funding Equity Act of 2004 on Property and Liability Insurance Companies
    • Statutory Accounting Practices and Taxable Income
    • Special Income Tax Provisions
    • GAAP Accounting for Income Taxes
    • Basic Principles of Accounting for Income Taxes
      • Changes in Tax Law
      • Financial Statement Presentation and Disclosure
    • Internal Control and Possible Tests of Control
      • Control Environment
      • Control Activities
      • Information and Communication
      • Substantive Procedures
    • Net Operating Loss and Tax Credit Carryforwards
    • Other Issues
      • Unrealized Gains and Losses
      • Accounting for the "Fresh Start"
      • The Alternative Minimum Tax
      • APB Opinion No. 23, Accounting for Income Taxes—Special Areas
      • Interim Financial Reporting
    • State Taxation
  • Chapter 8 - Reports on Audited Financial Statements
    • Reports on Financial Statements
    • Unqualified Opinions on GAAP Financial Statements
    • Unqualified Opinions With Explanatory Language
    • Emphasis of a Matter
    • Uncertainties
    • Going Concern
    • Qualified Opinion
    • Disclaimer of Opinion
    • Adverse Opinion
    • Additional Guidance When Performing Integrated Audits of Financial Statements and Internal Control Over Financial Reporting
    • Reporting on Whether a Previously Reported Material Weakness Continues to Exist
    • Auditors' Reports on Statutory Financial Statements of Insurance Entities
    • NAIC-Codified Statutory Accounting
    • General Use Reports
    • Limited Use Reports
    • General Use and Limited Use Reports
    • Special Reports
    • Special Reports on Loss Reserves
  • Appendix
    • A - Additional Audit Considerations for Loss Reserves, Premiums, Claims, and Investments
    • B - Illustrations of Auditing Objectives and Procedures
    • C - Illustrative Financial Statements and Disclosures
    • D - Auditor's Reports
    • E - NAIC Insurance Regulatory Information System (IRIS)
    • F - Examples of Development Data
    • G - Industry and Other Organizations
    • H - Statement of Position, Auditing Property and Liability Reinsurance
    • I - Statement of Position 90-10, Reports on Audited Financial Statements of Property and Liability Insurance Companies
    • J - Statement of Position 90-11, Disclosure of Certain Information by Financial Institutions About Debt Securities Held as Assets
    • K - Statement of Position 92-3, Accounting for Foreclosed Assets
    • L - Statement of Position 92-4, Auditing Insurance Entities' Loss Reserves
    • M - Statement of Position 92-5, Accounting for Foreign Property and Liability Reinsurance
    • N - Statement of Position 92-8, Auditing Property/Casualty Insurance Entities' Statutory Financial Statements—Applying Certain Requirements of the NAIC Annual Statement Instructions
    • O - Statement of Position 94-1, Inquiries of State Insurance Regulators
    • P - Statement of Position 94-5, Disclosures of Certain Matters in the Financial Statements of Insurance Enterprises
    • Q - Practice Bulletin 15, Accounting by the Issuer of Surplus Notes
    • R - Statement of Position 97-3, Accounting by Insurance and Other Enterprises for - Insurance-Related Assessments
    • S - Statement of Position 98-6, Reporting on Management's Assessment Pursuant to the Life Insurance Ethical Market Conduct Program of the Insurance Marketplace Standards Association
    • T - Statement of Position 98-7, Deposit Accounting: Accounting for Insurance and Reinsurance Contracts That Do Not Transfer Insurance Risk
    • U - Statement of Position 00-3, Accounting by Insurance Enterprises for Demutualizations and Formations of Mutual Insurance Holding Companies and for Certain Long-Duration Participating Contracts
    • V - Statement of Position 01-3, Performing Agreed-Upon Procedures Engagements That Address Internal Control Over Derivative Transactions as Required by the New York State Insurance Law
    • W - Statement of Position 01-5, Amendments to Specific AICPA Pronouncements for Changes Related to the NAIC Codification
    • X - Statement of Position 02-1, Performing Agreed-Upon Procedures Engagements That Address Annual Claims Prompt Payment Reports as Required by the New Jersey Administrative Code
    • Y - Information Sources
    • Z - Major Existing Differences Between AICPA Standards and PCAOB Standards
    • AA - Comparison of Key Provisions of the Risk Assessment Standards to Previous Standards
    • BB - Schedule of Changes Made to the Text From the Previous Edition
      • Glossary
      • Bibliography

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Excerpts

This AICPA Audit and Accounting Guide has been prepared by the AICPA Property and Liability Insurance Companies Task Force to assist preparers and auditors of financial statements. The guide assists practitioners in preparing financial statements in conformity with generally accepted accounting principles (GAAP) and assists auditors in auditing and reporting on such financial statements in accordance with generally accepted auditing standards or Public Company Accounting Oversight Board auditing standards.

Descriptions of accounting principles and financial reporting practices in Audit and Accounting Guides are approved by the affirmative vote of at least two-thirds of the members of the Accounting Standards Executive Committee (AcSEC), which is the senior technical body of the AICPA authorized to speak for the AICPA in the areas of financial accounting and reporting. AU section 411, The Meaning of Present Fairly in ConformityWith Generally Accepted Accounting Principles (AICPA, Professional Standards, vol. 1), identifies AICPA Audit and Accounting Guides that have been cleared by the Financial Accounting Standards Board (FASB) as sources of accounting principles in category b of the hierarchy of GAAP that it establishes. This Audit and Accounting Guide has been cleared by FASB. AICPA members should consider the accounting principles described in this Audit and Accounting Guide if the accounting treatment of a transaction or event is not specified by a pronouncement covered by Rule 203, Accounting Principles (AICPA, Professional Standards, vol. 2, ET sec. 203), of the AICPA Code of Professional Conduct. AICPA members should be prepared to justify departures from the accounting guidance in this guide, as discussed in paragraph .07 of AU section 411.*

AcSEC has found this guide to be consistent with existing standards and principles covered by Rule 202, Compliance With Standards (AICPA, Professional Standards, vol. 1, ET sec. 202), and Rule 203 of the AICPA Code of Professional Conduct. AICPA members should be prepared to justify departures from the accounting guidance in this guide.

Auditing guidance included in an AICPA Audit and Accounting Guide is an interpretive publication pursuant to AU section 150, Generally Accepted Auditing Standards (AICPA, Professional Standards, vol. 1). Interpretive publications are recommendations on the application of Statements on Auditing Standards (SASs) in specific circumstances, including engagements for entities in specialized industries. An interpretive publication is issued under the authority of the Auditing Standards Board (ASB) after all ASB members have been provided an opportunity to consider and comment on whether the proposed interpretive publication is consistent with the SASs. The members of the ASB have found this guide to be consistent with existing SASs.

The auditor should be aware of and consider interpretive publications applicable to his or her audit. If an auditor does not apply the auditing guidance included in an applicable interpretive publication, the auditor should be prepared to explain how he or she complied with the SAS provisions addressed by such auditing guidance.

FASB Accounting Standards Codification

On January 15, 2008, FASB launched the 1-year verification phase of the FASB Accounting Standards Codification™ (FASB ASC). After the verification period, during which constituents are encouraged to provide feedback on whether FASB ASC content accurately reflects existing U.S. GAAP for nongovernmental entities, FASB is expected to formally approve FASB ASC as the single source of authoritative U.S. GAAP, other than guidance issued by the Securities and Exchange Commission (SEC). FASB ASC includes all accounting standards issued by a standard-setter within levels A-D of the current U.S. GAAP hierarchy, including FASB, the AICPA, Emerging Issues Task Force (EITF), and related literature. FASB ASC does not change GAAP; instead it reorganizes the thousands of U.S. GAAP pronouncements into roughly 90 accounting topics and displays all topics using a consistent structure. The SEC guidance will follow a similar topical structure in separate SEC sections.

This edition of the guide has not been conformed to the new FASB ASC. AICPA Audit and Accounting Guides, as well as other AICPA literature, will be conformed to reflect FASB ASC after the verification phase and upon formal approval by FASB.

Defining Professional Requirements

AU section 120, Defining Professional Requirements in Statements on Auditing Standards, and AT section 20, Defining Professional Requirements in Statements on Standards for Attestation Engagements (AICPA, Professional Standards, vol. 1), which were issued in December 2005, set forth the meaning of certain terms used in SASs and Statements on Standards for Attestation Engagements (SSAEs), respectively, issued by the ASB in describing the professional requirements imposed on auditors and practitioners. The specific terms used to define professional requirements in these sections are not intended to apply to interpretive publications issued under the authority of the ASB because interpretive publications are not auditing or attestation standards. It is the ASB's intention to make conforming changes to the interpretive publications over the next several years to remove any language that would imply a professional requirement where none exists.

In December 2007, the Accounting and Review Services Committee (ARSC) also issued AR section 20, Defining Professional Requirements in Statements on Standards for Accounting and Review Services (AICPA, Professional Standards, vol. 2), which sets forth the meaning of certain terms used in Statements on Standards for Accounting and Review Services (SSARS) issued by ARSC in describing the professional requirements imposed on accountants performing a compilation or review of a nonissuer. The specific terms used to define professional requirements in this section are not intended to apply to interpretive publications issued under the authority of ARSC because interpretive publications are not SSARSs. It is ARSC's intention to make conforming changes to the interpretive publications to remove any language that would imply a professional requirement where none exists.

AU section 120, AT section 20, and AR section 20, which were effective upon issuance, define the terminology that the ASB and ARSC will use going forward to describe the degree of responsibility that the requirements impose on the auditor, practitioner, or accountant in engagements performed for nonissuers. SASs, SSAEs, and SSARSs will use the words must or is required to indicate an unconditional requirement, with which the auditor, practitioner, or accountant is required to comply. SASs, SSAEs, and SSARSs will use the word should to indicate a presumptively mandatory requirement. The auditor, practitioner, or accountant is required to comply with a presumptively mandatory requirement in all cases in which the circumstances exist to which the presumptively mandatory requirement applies; however, in rare circumstances, the auditor, practitioner, or accountant may depart from a presumptively mandatory requirement provided he or she documents the justification for the departure and how the alternative procedures performed in the circumstances were sufficient to achieve the objectives of the presumptively mandatory requirement. If a SAS, SSAE, or SSARS provides that a procedure or action is one that the auditor, practitioner, and accountant "should consider," the consideration of the procedure or action is presumptively required, whereas carrying out the procedure or action is not.

This guide has been updated as applicable for AU section 120, AT section 20, and AR section 20. Refer to the schedule of changes (appendix BB) for additional information.

Recognition

Benjamin S. Neuhausen, Chair Accounting Standards Executive Committee      Harold L. Monk, Jr., Chair Auditing Standards Board

Insurance Companies Committee (1988-1989)

Patrick W. Kenny, Chair
John T. Baily
William J. Bawden
Peter S. Burgess
Susan K. Evers
Ronald P. Freres
Wayne Kauth
R. Scott Malmgren
     Bruce K. Michelson
Ruben D. Nava
David D. Real
Gary Roubinek
Harold R. Simmons
Howard I. Smith
Mark H. Weston

2008 Conforming Changes Task Force

The AICPA staff gratefully acknowledges the significant contributions made by the following individuals in updating the May 1, 2008, edition of this guide.

Tom Fekete
(Deloitte)

Margaret Spencer
(RSM McGladrey, Inc.)

Noeleen Doelger
(Veris Consulting, LLC)

AICPA Staff

Willian S. Boyd
Technical Manager Accounting and Auditing Publications

Kim Kushmerick
Technical Manager Accounting Standards
     Hiram Hasty
Technical Manager Audit and Attest Standards

Lori Pombo
Technical Manager Accounting and Auditing Publications

Guidance Considered in This Edition

This guide has been modified by the AICPA staff to include certain changes necessary due to the issuance of authoritative pronouncements since the guide was originally issued. Relevant guidance contained in official pronouncements issued through May 1, 2008, has been considered in the development of this edition of the guide. This includes relevant guidance issued up to and including the following:

  • FASB Statement No. 161, Disclosures about Derivative Instruments and Hedging Activities—an amendment of FASB Statement No. 133
  • Revised FASB statements issued through May 1, 2008, including FASB Statement No. 141 (revised 2007), Business Combinations
  • FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes—an interpretation of FASB Statement No. 109
  • FASB Technical Bulletin 01-1, Effective Date for Certain Financial Institutions of Certain Provisions of Statement 140 Related to the Isolation of Transferred Financial Assets
  • FASB EITF consensus ratified by FASB through May 1, 2008
  • FASB Staff Positions issued through May 1, 2008
  • FASB Derivatives Implementation Group Statement 133 Implementation Issues cleared by FASB through May 1, 2008
  • Statement of Position (SOP) 07-1, Clarification of the Scope of the Audit and Accounting Guide Investment Companies and Accounting by Parent Companies and Equity Method Investors for Investments in Investment Companies (AICPA, Technical Practice Aids, ACC sec. 10,930); in February 2008, FASB deferred the effectiveness of this SOP indefinitely.
  • Practice Bulletin (PB) No. 15, Accounting by the Issuer of Surplus Notes (AICPA, Technical Practice Aids, PB sec. 12,150)
  • SAS No. 114, The Auditor's Communication With Those Charged With Governance (AICPA, Professional Standards, vol. 1, AU sec. 380)
  • SOP 07-2, Attestation Engagements That Address Specified Compliance Control Objectives and Related Controls at Entities That Provide Services to Investment Companies, Investment Advisers, or Other Service Providers (AICPA, Technical Practice Aids, AUD sec. 14,430)
  • PCAOB Auditing Standard No. 5, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements (AICPA, PCAOB Standards and Related Rules, Rules of the Board, "Standards")

Users of this guide should consider pronouncements issued subsequent to those previously listed to determine their effect on entities covered by this guide. In determining the applicability of a pronouncement, its effective date should also be considered.

The changes made to this edition of the guide are identified in appendix BB. The changes do not include all those that might be considered necessary if the guide were subjected to a comprehensive review and revision.

Auditing Guidance Included in This Guide

Risk Assessment Standards

In March 2006, the ASB issued SAS Nos. 104-111 (the risk assessment standards). Collectively, the risk assessment standards establish standards and provide guidance concerning the auditor's assessment of the risks of material misstatement (whether caused by fraud or error) in a nonissuer financial statement audit; design and performance of tailored audit procedures to address assessed risks; audit risk and materiality; planning and supervision; and audit evidence. The most significant changes to existing practice that the auditor will be required to perform are as follows:

  • Obtain a more in-depth understanding of the audited entity and its environment, including its internal control
  • Perform a more rigorous assessment of the risks of where and how the financial statements could be materially misstated (defaulting to a maximum control risk is not acceptable)
  • Provide a linkage between the auditor's assessed risks and the nature, timing, and extent of audit procedures performed in response to those risks

The statements are effective for audits of financial statements for periods beginning on or after December 15, 2006. Early adoption is permitted. See appendix AA in this guide for a more detailed comparison between the risk assessment standards and the existing standards. This guide has been conformed to the new risk assessment standards.

For additional guidance on the risk assessment standards, please refer to the AICPA Audit Guide Assessing and Responding to Risk in a Financial Statement Audit (product no. 012456) and the AICPA Audit Risk Alert Understanding the New Auditing Standards Related to Risk Assessment (product no. 022526).

Defining Professional Requirements

As previously stated, this guide has been conformed, as applicable, to the standards found in AU section 120, AT section 20, and AR section 20, which were effective upon issuance (December 2005, except for AR section 20, which was issued in December 2007). These new standards define the terminology that the ASB and ARSC will use going forward to describe the degree of responsibility that the requirements impose on the auditor, practitioner, or accountant in engagements performed for nonissuers. Refer to the schedule of changes, appendix BB, for additional information.

      * In May 2008, the Financial Accounting Standards Board (FASB) issued FASB Statement No. 162, The Hierarchy of Generally Accepted Accounting Principles, the objectives of which include moving responsibility for the U.S. generally accepted accounting principles (GAAP hierarchy) for nongovernmental entities from the AICPA's AU section 411, The Meaning of Present Fairly in Conformity With Generally Accepted Accounting Principles (AICPA, Professional Standards, vol. 1), to FASB literature. The FASB statement expands the sources of category a of the hierarchy of GAAP to include accounting principles that are issued after being subject to the FASB's due process (including, but not limited to, FASB Staff Positions and FASB Statement 133 Implementation Issues, which are currently not addressed in AU section 411).

      Among other matters, the FASB statement did not carry forward the Rule 203, Accounting Principles (AICPA, Professional Standards, vol. 2, ET sec. 203), exception from paragraph .07 of AUsection 411. Accordingly, the FASB statement states that an enterprise shall not represent that its financial statements are presented in accordance with GAAP if its selection of accounting principles departs from the GAAP hierarchy set forth in this statement and that departure has a material impact on its financial statements.

      In response to the original proposed FASB statement, in May 2005, the AICPA issued an exposure draft of a proposed Statement on Auditing Standards, Amendment to Statement on Auditing Standards No. 69, The Meaning of Present Fairly in Conformity With Generally Accepted Accounting Principles, for Nongovernmental Entities for Nongovernmental Entities, which deletes the GAAP hierarchy for nongovernmental entities from AU section 411. The Public Company Accounting Oversight Board (PCAOB) has already taken measures to remove the GAAP hierarchy from its interim auditing standards in a set of amendments which it adopted on January 29, 2008. The amendments, if approved by the Securities and Exchange (SEC), will become effective 60 days after SEC approval.

      For more information please visit the FASB Web site at www.fasb.org and the PCAOB Web site at www.pcaob.org.

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