2 pages. Excerpt: On behalf of the HR Policy Association, I am writing to urge the Financial Accounting Standards Board ('FASB) to reverse the FASB staff's recently articulated view on the definition of 'grant date'under Statement of Financial Accounting Standards No. 123 (as revised, 2004) ('FAS 123R'). We believe that the staff's interpretation would create significant unintended consequences that significantly outweigh any accounting benefits that are produced.