On March 8 BPI submitted a comment letter to the FASB supporting the FASB’s proposal to simplify the transition to CECL implementation. BPI supported the use of a one-time irrevocable option to elect the fair value option for financial instruments measured at amortized cost but also recommended that FASB permit a one-time transfer of securities out of the held-to-maturity portfolio into the available for sale or trading portfolios, and out of the available for sale portfolio into the trading portfolio, which would allow for transition relief consistent with the transition relief afforded upon the adoption of other new accounting standards.
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