Weakening the materiality standard and increasing regulatory deference to issuer and auditor judgments has long been a goal of the preparer community.  These efforts have been strongly resisted by investors and investor advocates.  It is disappointing, to say the least, to see FASB put forward a proposal that is so clearly intended to advance this anti-investor, anti-transparency agenda. CFA urges FASB to withdraw the current proposals and start from scratch with an assessment of whether, from the point of view of users of financial reports, there is even a problem here that needs to be addressed.  Any such evaluation must give due consideration to the question of whether existing standards for applying materiality are too lax, rather than too rigorous. To the extent that the Board finds that problems with application of materiality exist, CFA urges the board to adopt an approach that focuses on the needs of users of financial reports and prioritizes full and fair disclosure over reduced disclosure.