Letter to FASB on the Post‑Implementation Review of the CECL Accounting Standard

RE: Post‑Implementation Review of the CECL Accounting Standard

Dear Mr. Day:

The American Bankers Association (ABA) appreciates the opportunity to comment in anticipation of the upcoming public roundtable being conducted as part of the Financial Accounting Standards Board's (FASB) Post‑Implementation Review of the Current Expected Credit Losses (CECL) standard. As the national voice for America's banks, including thousands of community institutions, we have gathered extensive feedback through roundtables, member surveys, and direct conversations with bankers, auditors, and users of financial statements.

Our letter updates one of the main concerns ABA expressed prior to the 2020 effective date. Our update is not intended to point out specific flaws in the CECL standard, but to shine light on how the CECL standard has been applied in practice by community bankers under the supervision of banking regulators, and auditing firms.

Download the comment letter to read the full text.

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Letter to FASB on the Post‑Implementation Review of the CECL Accounting Standard

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