The Clearing House Association submitted a comment letter to the BCBS focused on the financial accounting and reporting aspects of their consultative document titled “Guidance on Accounting for Expected Credit Losses.” TCH generally applauds the efforts of the BCBS in issuing guidance to reinforce and enhance sound credit risk practices as they relate to accounting, and particularly supports the principles-based accounting approach generally taken in the Proposal. Because, however, a final expected credit losses standard has yet to be released in the U.S., we believe this guidance is premature and should be reissued as a formal NPR by the U.S. standard setting agencies following implementation of an expected credit losses standard in the U.S. TCH also notes several other areas of concern, including: (i) inputs/assumptions used in developing regulatory capital should not necessarily be the same as those used for accounting measures, (ii) the use of practical expedients should be permitted, and (iii) all disclosure requirements should take into account current requirements by domestic standard setters.
You Might Also Be Interested In...
Cybersecurity
Financial Trades Call for Accessible, Functional and Simple Cyber Incident Reporting Rules
Security
BPI Comments on NYDFS Proposal on Cybersecurity Requirements for Financial Services Companies
Regulatory Reporting and Accounting
BPI Comments to Banking Agencies on Reporting of Notional Pool Balances on Schedule RC-O of the Call Reports
Regulatory Reporting and Accounting
BPI and IIB Comment on Federal Reserve Proposal to Revise FR Y-7Q Capital and Asset Report for Foreign Bank Organizations
More Posts by This Author
AML, Bank Secrecy Act and Sanctions
BPI’s Heather Hogsett Testifies Before House Subcommittee on Cybersecurity, CISA’s Contributions
AML, Bank Secrecy Act and Sanctions
FinCEN Must Preserve Beneficial Ownership Data Usefulness, Discourage Inappropriate Reporting Omissions