Matters for Comment

LSC seeks public comments on a variety of proposals affecting LSC grants and operations.  

For items with closed comment periods, please see the Closed Comment Period page. 

The Rulemaking section of Laws, Regulations & Guidance contains information about open and closed LSC rulemakings (changes to the LSC Regulations).

LSC will post comments at www.lsc.gov. Personally identifiable information may be redacted upon request, and LSC may redact third-party personal information. Comments are also subject to FOIA disclosure without redaction.

Draft Financial Guide

Comments are due on or before the close of business on October 15, 2020.

Stuart Axenfeld, LSC’s Deputy Director for Fiscal Compliance, will discuss the draft Financial Guide at the MIE Financial Essentials Training in September.

Electronic  submission of comments are  preferred  via  email  with  attachments  in  Acrobat  PDF format. LSC may not consider written comments sent via any other method or received after the end of the comment period.

Please submit comments to: financialguide@lsc.gov.
Please include “Financial Guide Comment” in the subject line of the message.

For other methods of submitting comments, or for more information, please contact Mark Freedman, Senior Associate General Counsel, at (202) 295-1623 or mfreedman@lsc.gov.

LSC has conducted a comprehensive review and overhaul of the Accounting Guide for LSC Recipients, 2010 Edition.  Based on input from LSC grantees and LSC fiscal compliance analysis staff, LSC believes that the format of the Accounting Guide no longer best serves grantees or LSC.  LSC has restructured the document and renamed it the Financial Guide.  The new draft Financial Guide removes outdated or inapplicable materials, improves materials directly related to LSC-specific issues, and adds clarity about both required and recommended financial practices.  The draft Financial Guide also addresses areas that were previously identified as problematic, such as Cost Allocation, and assists grantees in the financial management of LSC grants.  LSC seeks public comment on the draft Financial Guide, as per the information and instructions below.

LSC has removed sections that provided general accounting and financial guidance because neither LSC nor grantees found these sections useful.  The Financial Accounting Standards Board (FASB) establishes and updates the generally accepted accounting principles (GAAP) that provide the applicable accounting methods and practices.  The draft Financial Guide references GAAP requirements rather than restating them.

Overall, the draft Financial Guide conforms to existing LSC and grantee practices and requirements. Additionally, in some places, the draft Financial Guide sets out requirements that have not previously been published for comment. 

The Reference Guide to Updates and New Requirements in the link below includes a table that identifies sections and materials that LSC has significantly updated or are entirely new; LSC has also made other changes that are less significant.  LSC seeks comments on the entire draft Financial Guide with emphasis on the sections with significant changes.  LSC will review the comments and, if possible, implement the Financial Guide, with any appropriate revisions before January 1, 2021.

LSC also seeks comment on the following question:

Should LSC implement the new Financial Guide as of a single date for all grantees (e.g., January 1, 2021) or by applying it to each grantee with the start of the grantee’s new fiscal year. 

LSC looks forward to your comments and feedback.