Joint Trades Letter to Treasury Department, OCC, FDIC and Federal Reserve on SEC SAB 121

Nellie Liang
Under Secretary for Domestic Finance
Department of the Treasury
1500 Pennsylvania Avenue NW
Washington, D.C. 20220

Mark E. Van Der Weide
General Counsel
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, D.C. 20551

Harrel Pettway
General Counsel
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, D.C. 20429

Benjamin W. McDonough
Senior Deputy Comptroller and Chief Counsel
Office of the Comptroller of the Currency
400 7th Street SW
Washington, D.C. 20219

Ladies and Gentlemen:

The American Bankers Association, Bank Policy Institute and the Securities Industry and Financial Markets Association (the “Associations”) write to call attention to issues arising from the new Staff Accounting Bulletin No. 121 (“SAB 121” or “the SAB”) issued by the staff (“SEC Staff”) of the Office of the Chief Accountant of the Securities and Exchange Commission (the “SEC”). In particular, this letter and its appendices follow preliminary discussions that the Associations have had with SEC Staff, and staff of the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Federal Reserve Board (the “FRB” and, collectively with the OCC and the FDIC, the “Banking Agencies”) and Department of the Treasury, and respond to staff requests for more information and analysis.

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