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
Regulatory Reporting and Accounting BPI Comments on Fed Proposal to Revise Structure Reporting and Recordkeeping Requirements for Domestic and Foreign Banking Organizations
More Posts by This Author
Bank Capital and Stress Testing BPI Response to Federal Reserve Vice Chair Barr’s Statements on Bank Capital Requirements
Supervision & Enforcement FDIC’s Proposed Changes to Supervisory Appeals System Fall Short of Progress
Supervision & Enforcement BPI and Trade Coalition Comment on FDIC Guidelines for Appeals of Material Supervisory Determinations