Skills for Accounting and Auditing Research
Case Study 1.3－J.P. Morgan Chase & Co.
1. J.P. Morgan identifies itself as a user and a preparer. There is no doubt that J.P. Morgan prepares its own financial statements; in addition, J.P. Morgan also serves as a significant user of other entities’ financial statements.
2. J.P. Morgan questions that FASB proposes to make fundamental changes on ASC450 may let companies to disclose confidential, privileged and sensitive information.
3. J.P. Morgan raises four concerns in this comment letter.
(1) Prejudicial exemption and public information－J.P. Morgan concerns that the ED doesn’t make clear exemption from disclosing information that may do harm to companies.
(2) Attorney-client privilege－J.P. Morgan thinks that the existing disclosing requirement of claim amounts is generally appropriate. Too much additional information of claim amounts would allow the opposing parties to use this information and waive attorney-client privileges.
(3) Tabular reconciliation of recognized loss－J.P. Morgan believes that tabular reconciliation of recognized loss contingencies would provide too much detailed information for courts and opposing parties, which may jeopardize the entities for their pending litigation, especially when disclosing quarterly.
(4) Remote loss contingencies－J.P. Morgan states that there is no need to disclose remote loss contingencies. If we comply with the ED that all loss contingencies should be disclosed, it’s hard for investors to distinguish material and immaterial information.
4. J.P. Morgan believes that the existing ASC 450 disclosure requirements not only provide sufficient information to investors, but also protect confidential, privileged and sensitive information of entities. Therefore, it's not necessary to issue ED.