On Tuesday, BPI submitted a comment letter to the Financial Accounting Standards Board (“FASB”) on its proposed changes and clarifications to three current GAAP accounting standards (financial instruments, derivatives and hedging, and credit losses (“CECL”)). Of note, the letter argues that the FASB should either eliminate the suggestion in the proposal that held-to-maturity debt instruments are nonmonetary balance sheet items or else issue a separate proposal on that issue. Additionally, the letter holds that accounting changes made as of the CECL adoption date regarding the allowance for interest receivables and/or relating to nonaccrual policies should be recorded as an adjustment to shareholder’s equity rather than the income statement.
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