NASPP Comment Letter on Grant Date Under FAS 123(R)

The NASPP has submitted a comment letter to the FASB in response to our members’ concerns regarding the FASB staff’s recent interpretation of the determination of grant date under FAS 123(R). We heard from many of you that this issue is of significant concern, requiring drastic and onerous modifications to your grant communication procedures while providing little substantive benefit. We worked with leading industry practitioners to draft a comment letter expressing those concerns while also providing support for an alternative interpretation that would treat the board approval date as the grant date for most equity awards.

Read our comment letter.

The NASPP thanks Mark Borges and Susan Eichen of Mercer Human Resource Consulting, Paula Todd and Diana Scott of Towers Perrin, Robbi Fox of Hewitt Associates, and Louis Rorimer of Jones Day for invaluable assistance with our comment letter.

More Analysis Available

More information on how this issue affects your company, along with memos from leading practitioners, is included in our full analysis of this development in the NASPP’s Stock Plan Expensing portal.

Learn even more about this and other important new FAS 123(R) developments at the 2005 NASPP Annual Conference. The Conference will feature a keynote address by Bob Herz, Chair of the FASB, and eight sessions on FAS 123(R).  Don’t miss the session—"The FASB Speaks"—where a key representative on the FASB staff will provide guidance on this and other implementation issues.