Letter to FASB on Purchased Financial Assets

Hillary Salo
Technical Director
Financial Accounting Standards Board
801 Maine Ave
P.O. Box 5116
Norwalk, CT 06856-5116

Dear Ms. Salo:

The American Bankers Association (ABA) welcomes the opportunity to comment on Proposed ASU on Financial Instruments - Credit Losses (Topic 326) Purchased Financial Assets (ED). This letter is to document on behalf of ABA and our members our intention to provide comments after the stated August 28, 2023 due date and no later than September 20, 2023.

ABA appreciates the Financial Accounting Standards Board (FASB, or the "Board") efforts to encourage input on the Board's projects. ABA has discussed our concerns with FASB regarding the ability to provide well developed feedback within the allotted 60 days. These concerns are due to both timing of the comment period and the complexity of certain issues ABA and our member institutions believe will take time and effort to fully develop and socialize with their key stakeholders.

In our discussions with FASB regarding these concerns, they indicated a priority in obtaining feedback that is well developed and that such feedback provided within a reasonable period of time after August 28 is welcome and will be fully considered. ABA indicated to FASB that we, many of our members, and other stakeholders intend to provide comments as late as September 20, 2023. In response, no objection was noted.

If you need additional information or have questions, please contact me ([email protected]; 202-663-5318).

Sincerely,
Joshua Stein