The Clearing House (TCH) has submitted a comment letter to the FASB in response to the consultative document, Changes to the Disclosure Requirements for Fair Value. While TCH is supportive of efforts to improve existing standards, and in particular allowing preparers to apply materiality determinations at their own discretion, the comment letter expresses significant concerns with the proposed additional disclosure requirements related to unrealized gains and losses for Level 1 and Level 2 fair value measurements. The letter states that disclosure of the additional information being proposed would not be decision-useful to stakeholders, in some cases would be misleading, and the costs associated with these disclosures would outweigh any perceived benefits. If these disclosure requirements were to be finalized, the letter advises that entities will need at least two years from the date the proposal is finalized to allow for sufficient time to implement new systems to provide the information requested.
You Might Also Be Interested In...
Regulatory Reporting and Accounting BPI Response to FDIC Resolution Plans Required for Insured Depository Institutions With $100 Billion or More in Total Assets
Regulatory Reporting and Accounting BPI Recommends Call Report Changes to Address Troubled Debt Restructuring
Cybersecurity Redundant Reporting Stresses Banks’ Cybersecurity Readiness, Warrants White House Review
Cybersecurity BPI and ABA Recommend Office of the National Cyber Director Harmonize Cyber Regulations
Regulatory Reporting and Accounting BPI and Coalition of Trades Oppose PCAOB’s Proposed Changes to Auditing Standards
More Posts by This Author
Basel Finalization The Empire Strikes Back: How the Basel Proposal Would Shift Credit Allocation from the Private Sector to the Government
Consumer Affairs Banks Support National Strategy to Identify Opportunities and Barriers to Financial Inclusion
Bank Liquidity BPI Statement for the Record for House Hearing on the Fed Discount Window and Emergency Lending
AML, Bank Secrecy Act and Sanctions BPI Statement for the Record for House Oversight Hearing of FinCEN and the Office of Terrorism and Financial Intelligence