The Clearing House Association submitted an unsolicited comment letter to the FASB in advance of the February 11 FASB Board meeting at which they would be redeliberating their ‘Financial Instruments – Credit Losses’ proposal and potentially expanding current disclosure requirements by requiring additional tables that would require entities to track financial assets by date of origination (i.e., vintage disclosures). The TCH letter urged FASB to consider alternatives to this approach, such as enhancing existing credit quality disclosures including, where appropriate, requiring additional disclosures of certain higher risk loan portfolios. At the February 11 Board meeting, the Board decided to proceed with expanded disclosures without an exposure draft by requiring balances to be disaggregated based on originations, but did indicate they will be performing extended outreach about vintage disclosures.
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