SEC Comment Letter Correspondence of Cost Accounting

High School ・Accounting ・APA


From: (Your name)

Date: September 12, 2017

Subject: The Analysis of The First Long Island Corporation’s Response to Accounting Queries

Company: Long Island Corporation

CIK: 740663

Date of original SEC comment letter: August 9th, 2017

Date of company response letter: September 7th 2017

The first long Island corporation with regards to accounting, particularly executive employment compensation has been made to go through an analysis process using the comment letter. There has been an accounting issue that was tendered regarding the compensatory arrangements between the three executives, Long Island corporation and the First National Bank of Long Island. Moreover Furthermore, the First Long Island corporation is the holding company for the First National Bank of Long Island. The Bank provides services to individual, professional, corporate, institutional and Government customers. Although there was an initial agreement between Richard Kick, Mark D. Curtis and Donald L. Manfredonia to be the executives of the company with the management of the first long Island Corporation with regards to accounting, particularly executive employment compensation.

  1. The accounting issue in question is regarding the compensatory arrangements between the three executives, Long Island Corporation, and The First National Bank of Long Island. There was an initial agreement signed between Richard Kick, Mark D. Curtis and Donald L. Manfredonia as the company executives with the management of The First Long Island Corporation specifying the terms and the period of employment. The initial agreement was to come to an end by December 31, 2009, and the cause of concern for the three executives was how best they could renew their contract with the initial terms of employment compensation. The First Island Corporation was adamant on sticking with the initial terms in the process of renewing the executive contract but the executive employees insisted on having the terms altered before the contract renewal.

The cause of concern was whether the employment agreement that was entered before on January 1, 2005, could be still held under this new employment contract. The executives, however, stated clearly that the initial terms of the previous contract were meaningless since the new contract is in place.

  1. The SEC staff identified the accounting issue in relation to compensation through review of the new contract of employment where the Company had not clearly disclosed under what terms the executives could renew their contract.
  2. The case was resolved when The First of Long Island Corporation send all the details of the compensation agreement to the Securities Exchange Committee showing how the executive compensation would be accounted for during the employment period. All the benefits that the executives would receive were highlighted in the agreement to show how the company was committed to meeting most of the demands that had been raised to the committee.
  3. The key to resolving the issue was that the accounting for stock-based compensation requires that public companies apply the fair value accounting approach whereby the employees’ earnings from shares and base income are disclosed. Besides, one of the executives, Mark D. Curtis, certified that indeed the information provided by the company to the commission is true to his knowledge. The company applied the fair share principle of accounting to disclose all the compensatory arrangements with its executive members thus addressing the issue of mistrust or false information.
  4. I agree with the resolution in addressing the issue of compensation for the executive. Initially, the information that was in the public domain was different from the truth contained in the employment agreement. This is because people thought that executives would still be compensated as per the older employment agreement of 2005 but in reality, the terms of the new agreement were completely different from the initial one. Therefore, the disclosure of the information contained in the new employment agreement was the best solution to address the issue.
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