Letter to FASB on the Invitation to Comment, Agenda Consultation

Dear Mr. Day:

The American Bankers Association (ABA) welcomes the opportunity to comment on the invitation to comment exposure document - Invitation to Comment, Agenda Consultation ("the Exposure Document," or "ITC"). The ITC requests feedback on the future standard-setting agenda of the Financial Accounting Standards Board ("FASB," or "the Board"). As both users and preparers of financial statements, bankers have a keen interest in FASB's agenda.

This ITC highlights the Board's strong commitment to accessibility and stakeholder engagement. ABA appreciates FASB's commitment to proactively seeking input from a broad spectrum of stakeholders, including investors, preparers, auditors, academics, and industry groups—on the prioritization of future standard-setting activities. This initiative exemplifies how FASB provides multiple avenues for stakeholders to influence its technical agenda and ensure that standard-setting reflects the evolving needs and concerns of the financial reporting community.

As the Board considers how to best to address user needs in future projects, it may be helpful for the FASB to take into account other tools available within the broader U.S. disclosure framework that may meet those needs. Companies already provide, and are expected to continue providing, decision-useful information to investors outside of the U.S. GAAP financials—such as through SEC filings (e.g., risk factors and MD&A), investor presentations, earnings calls, and direct communications with investor relations teams. ABA believes there are opportunities outside of formal standard setting to meet investors' needs while simultaneously reducing the strain on the Board's resources.

In carefully considering the stated objectives of the invitation to comment, our feedback identifies 1) opportunities to more closely align underlying economics with accounting outcomes 2) opportunities to balance costs relative to benefits and, 3) topic areas ABA does not believe a project should be added.

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