Accounting Resources on the FASB and IASB Proposals

ABA Comment Letters

• Summary of ABA Comment Letter regarding the FASB proposal
• ABA's Comment Letter to the IASB regarding IASB's exposure draft on impairment (June 2010)
• ABA's Comment Letter to the IASB regarding IASB's (pre-exposure draft initial) request for information on impairment
• ABA's Comment Letter to the IASB's exposure draft "Hedge Accounting" (March 2011)
• ABA's Comment Letter to the IASB and FASB regarding the Supplementary Document "Impairment" (April 2011)

Understanding the Proposals

• Summary of the FASB proposal.
• Comparison of the FASB proposal to the IASB model and the current U.S. GAAP.
• Copy of the Exposure Draft (218 pages),
• ABA's Telephone Briefing for ABA's Telephone Briefing "FASB's Mark to Market Proposal: What You Must Know"
• The IASB's final standard to download the IASB's final standard (issued Nov 2009) IFRS 9 Financial Instruments on Classification and Measurement.
• The IASB's exposure draft Financial Instruments: Amortized Cost and Impairment (comments due June 30, 2010).

See What Others say about Mark to Market Accounting

• "U.S. Institutional Investors Strongly Oppose FASB Proposal on Fair Value for Bank Loans", a survey by Keefe, Bruyette & Woods and Greenwich Associates (October 2010)
• "OCC's Investor Roundtable on FASB's Exposure Draft" a research report by Stifel Nicolaus (July 2010)
• The PricewaterhouseCoopers Survey, "What Investment Professionals Say about Financial Instrument Reporting" (June 2010)
• Commentary on Mark-to-Market Accounting by William M. Isaac, former Chairman of the FDIC, published in Forbes Magazine.
• Former Federal Reserve Chairman Paul Volcker's comments on the FASB mark to market proposal, recorded for his June 14, 2010 interview with William Isaac and Larry Kudlow on CNBC. View the complete interview.
• Recommendations from banking regulators worldwide. (Basel Committee on Banking Supervision).
• IASB Project Summary and Feedback Statement regarding the issuance of IFRS 9: Classification and Measurement, which addresses mark to market accounting (November 2009).
• Commentary from FDIC Chairman Sheila Bair on Mark-to-Market Accounting, published in Forbes magazine.

Bankers Concerns on Mark to Market Accounting

• ABA Position Paper on the "Loan and Debt Securities Accounting:  Principles to Follow in Developing a New Model", published August 2009.
  
  This paper explains the historical, theoretical, and practical reasons why bankers support a "business model" approach to accounting.  The arguments are based primarily based on the criteria that accounting standard setters, themselves, use in setting standards:  the information must be relevant and must be reliable.
  
  
• ABA White Paper on the "Current Pace and Direction of Accounting Standard Setting", published August 2009.
  
  This paper examines and compares the general directions both the International Accounting Standards Board (IASB) and the Financial Accounting Standards Board (FASB) were taking as of August 2009.  These directions are also compared to the recommendations provided by various organizations that were active in studying the Financial Crisis and include the G-20, the G30, The Financial Stability Board, and the U.S. Department of Treasury.  The final IASB direction was ultimately modified from their initial exposure draft (see other links for their final decisions).  However, the FASB direction to be presented in their May 2010 exposure is expected to be consistent with that position detailed in the paper.
  
  
• International Banking Federation's (IBFed) Accounting for Financial Instruments Conceptual Paper" (April 2008).
  
  The IBFed (of which ABA is a founding member) is a representative body for banking associations around the world and includes representation from the U.S., Canada, Europe, Australia, and Japan.  This conceptual paper examines mark-to-market accounting as a performance reporting system.

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Questions? Please contact Mike Gullette, Vice President, Accounting and Financial Management.