1. What is goodwill, or in your experience what does Goodwill mainly represent?

2. Does the benefit of the information provided by the current goodwill impairment model justify the cost of providing that information? Please explain why or why not in the context of costs and benefits.

3. On a cost-benefit basis, relative to the current impairment-only model, do you support (or oppose) goodwill amortization with impairment testing? Please explain why in your response.

4. If the board were to decide to amortize goodwill, which amortization period characteristics would you support? Please include all that apply in your response and explain why you did not select certain characteristics.

a. A default period

b. A cap (or max) on the amortization period

c. A floor (or minimum) on the amortization period

d. Justification of an alternative amortization period other than a default period

e. Amortization based on the weighted-average useful lives of the identifiable asset(s) acquired

f. Amortization based on weighted-average useful lives of the identifiable asset(s) acquired

g. Management reasonable estimate (based on expected synergies or cash flows as a result of the business combination, the use of acquired processes, or other management judgments)

5. Do your views on amortization versus impairment of goodwill depend on the amortization method and/or period? Please indicate yes or no and explain.

6. Regarding the goodwill amortization period, would equity investors receive decision-useful information when an entity justifies an amortization period other than a default period? If so, does the benefit of this information justify the cost (whether operational or other types of cost)? Please explain.

7. Do the amendments in update 2017-04 (eliminate step 2 of the goodwill impairment test) reduce the cost to perform the goodwill impairment test? Do the amendments in Update 2017-04 reduce the usefulness of financial reporting information for users? Please explain.

8. Do the amendments in Update 2011-08 (qualitative screen) reduce the cost to perform the goodwill impairment test? Do the amendments in Update 2011-08 reduce the usefulness of financial reporting information for users? Please explain and describe any improvements you would recommend to the qualitative screen.

9. Relative to the current impairment model how much do you support (or oppose) removing the requirement to assess goodwill (qualitative or quantitatively) for impairment at least annually? Please explain why in your response.