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.
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