On July 20, 2010, FASB published an Exposure Draft addressing employer reporting of potential loss contingencies regarding its withdrawal from multiemployer plans (the "Loss Contingency Exposure Draft").

The new proposal will require significantly more employers to report potential withdrawal liability without regard to the practical probability that it will be incurred and without regard to whether an exception to the assessment of withdrawal liability is available under ERISA.

Not only do the contemplated changes require the provision of additional quantitative information which is stale, expensive to present, and misleading, it also asks for speculative qualitative statements regarding expected future increases and the presentation of funding scenarios which are being merely "considered." Specifically, the FASB staff recommended the following changes be included in the FASB Multiemployer Exposure Draft and the board has approved their recommendations:

1. Expected future trends in contributions, if known, including the extent to which a surplus or deficit in the plan may affect future contributions;
2. A narrative description, including the expected effect, of any funding improvement plan or rehabilitation plan. For plans in regulatory warning zones (for example, "critical" or "endangered" status as defined by the Pension Protection Act of 2006) the warning status and possible remedies being considered by the plan, if known;
3. A narrative description of the entity's exposure to significant risks arising from its participation in the plan, for example the extent to which the entity can be liable to the plan for other participating employers' obligations under the terms and conditions of the plan, the entity's inability to influence the plan's investment decisions and consequences the entity might face if it ceased contributing to the plan; and
4. Details of any agreed deficit or surplus allocation on wind-up and, if applicable and available, the amount that is required to be paid on withdrawal as of the most recent date available. For plans where the amount required to be paid on withdrawal is applicable, but not available, an entity shall provide information about the magnitude of those plans (such as the percentage of the multiemployer plan contributions to such plans, or percentage of participants covered by such plans). The IASB Exposure Draft suggests even broader changes regarding both qualitative and quantitative information, regardless of whether that information is available to the employer. Due to the convergence of international accounting standards, both the FASB and IASB proposals need to be addressed.

Below are comments that National FCA and the Quality Construction Alliance (QCA) submitted to FASB regarding FASB's Standards Proposal.