The Clearing House Association, jointly with the ABA, submitted a comment letter to the FASB in response to Proposed Accounting Standards Update issued on August 6 to simplify evaluating puts/calls. TCH is supportive of the proposal which clarifies the requirements in assessing contingent put and call options that are embedded within certain debt instruments. The letter also supports allowing banks to choose whether to implement the guidance on a prospective or retrospective basis.
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