5/11/2004: Frederic W. Cook & Co., Inc. Comment Letter to Financial Accounting Standards Board on FASB Draft: Share-Based Payment (PDF)

FW Cook

3 pages. Excerpt: If the FASB is to impose an earnings charge on financial statements for the value of employee stock options at grant, it is important that the method chosen for measuring that value be fair and reasonable, reflect real economic values and costs, and be comparable across various industry sectors. It is unclear whether the proposed models, which were developed for transferable options and warrants with relatively short terms, meet these criteria.

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