Re: File Reference No. 2019-770. Proposed Accounting Standards Update Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting.
Russell G. Golden
Chairman
Financial Accounting Standards Board
401 Merritt 7
P.O. Box 5116
Norwalk, CT 06856-5116
The Securities Industry and Financial Markets Association’s (“SIFMA”) Accounting Committees and the American Bankers Association’s (“ABA”) Accounting Committee thank you for the opportunity to respond to the Financial Accounting Standards Board’s (“FASB’s” or “Board’s”) request for comment on the proposed Accounting Standards Update Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting (the “ASU”).
We appreciate the FASB’s considerable industry outreach, technical research, and the accelerated timeline in which they have addressed this unique change that will significantly impact the financial markets.
SIFMA and its member firms have coordinated with The Alternative Reference Rates Committee (“ARRC”) Accounting and Tax working group and are submitting a joint comment letter on the ASU. In this letter. SIFMA has joined with ABA to provide additional comments and recommendations with respect to the ASU regarding disclosures, which was not addressed in the joint comment letter with the ARRC.
