The Clearing House Association submitted an unsolicited letter to the FASB in response to the notice that the Board would continue redeliberations of its Financial Instruments exposure draft at the April 4 board meeting. The FASB has previously expressed a desire to limit the Recognition and Measurement Proposal, originally issued in February 2013 to improve financial reporting by providing framework for classifying and measuring financial instruments, to targeted improvements to the existing Accounting Standards Codification. TCH made the following suggestions on targeted areas of improvement: (i) the fair value option is not in need of improvement and should not be limited, (ii) all purchased loans should be treated the same, (iii) the TDR disclosures are no longer meaningful and should be eliminated, (iv) sales of loans from the “Held-for-Investment” portfolio should not be further restricted, and (v) foreign currency gains and losses on debt securities measured at fair value through other comprehensive income (FVOCI) should be recognized in net income.
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