Silence is Acceptance

A project team I worked on several years ago adopted a saying – “Silence is Acceptance.”  This is akin to another saying I’ve heard which is “speak now or forever hold your piece,” but really goes further.  I mean you can disagree with something, but still choose to not ever express those disagreements.  It’s another thing altogether to say not only will you not express disagreement, but in fact your silence is professing agreement with the subject of discussion.

This issue was brought to mind when I was listening to a FASB discussion on comment letters related to their proposed changes to pension accounting.  One board member pointed out that they only received 36 comment letters on the topic and therefore the lack of a substantial number of comment letters meant that most preparers, auditors and users must have agreed with the FASB’s position.  I would like to point out that it’s possible that many preparers, auditors and users of financial statements don’t deal with pension accounting much anymore.  Defined benefit pension plans seem to be going the way of the buggy whip.  Yes a few still exist and even fewer are actually active and open to new participants, but many CPAs can now go their whole career without touching the accounting for a defined benefit pension plan.  But nonetheless, they all must agree with the FASB because they didn’t bother to write a comment letter.

I write this because I hear from so many of my colleagues about their disagreement with a decision made by the FASB, the PCAOB, the ASB or the SEC, and yet when I ask them if they commented when the rule was proposed the answer is almost invariably, no.  I know we are all busy people, but if you don’t let your opinions be heard then remember, silence is not just about “holding your piece,” it’s about “acceptance;” at least in the mind of all those standard setters out there.

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