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ABA: The American Bankers Association

Michael L. Gullette

SVP, Tax & Accounting

Mike Guillette
  • Podcast
    Ensuring a Smooth CECL Transition

    June 22, 2021

    Brought to you by: Keith E. Monson and Mike Gullette

  • Comment Letter
    ABA Comment to SEC re: Climate Change Disclosure

    June 11, 2021

    RE: Climate Change Disclosure Request for Input

  • Podcast
    Pooling and Modeling in CECL

    June 09, 2021

    ARCSys has been addressing credit losses and the complex CECL standards with the most robust software solution since 2009. ARCSys offers a Concierge Implementation Service that includes loading, validating, segment recommendations, and statistical forecasted models

  • Comment Letter
    ABA Letter to SASB on Conceptual Framework

    December 22, 2020

    The American Bankers Association (ABA) appreciates the opportunity to comment on the Exposure Draft Proposed Changes to the SASB Conceptual Framework and Rules of Procedure (Proposal).

  • Comment Letter
    ABA Letter to IFRS re: Consultation on Sustainability

    December 22, 2020

    The American Bankers Association (ABA) appreciates the opportunity to comment on the Consultation Paper on Sustainability Reporting (the Paper).

  • Comment Letter
    ABA Letter to Treasury re: Mandated Study of the CECL Accounting Standard

    July 30, 2020

    The American Bankers Association (ABA) thanks Congress, the Federal banking agencies and the Treasury department for their work throughout this unprecedented national health crisis to address the various issues that impede banks’ efforts to serve borrowers.

  • Comment Letter
    ABA Comment Letter to AICPA re: Proposed Statement on Auditing Standards – Auditing Accounting Estimates and Related Disclosures

    December 10, 2019

    The American Bankers Association appreciates the opportunity to comment on the Proposed Statement on Auditing Standards – Auditing Accounting Estimates and Related Disclosures (the Proposal). We are commenting on this Proposal due to the potential implications the final standard may have on audits of banks.

  • Position Paper
    ABA Discussion Paper on “The Need for a CECL Quantitative Impact Study”

    September 13, 2019

    <p>The banking industry has requested that a quantitative impact study be performed prior to the 2020 implementation of CECL. The study would include the top ten lenders in each major lending product, plus Fannie Mae and Freddie Mac, as well as a range of midsize and community banks, using actual bank modeling, forecasting results as they would likely have occurred during the financial crisis time period (December 2005 through 2010). Including these lenders would cover the majority of loans held in the regulated lending industry. The results can be summarized, extrapolated to an impact on lending as well as on individual institutions throughout the remainder of the industry.</p>

  • Comment Letter
    Comment Letter to AICPA on “Audit Evidence”

    September 13, 2019

    <p>The American Bankers Association (ABA) appreciates the opportunity to comment on the Proposed Statement on Auditing Standards – Audit Evidence (the Proposal). We are commenting on this Proposal due to the potential implications the final standard may have on audits of banks.</p>

  • Comment Letter
    Comment Letter to FASB on CECL Effective Date

    September 13, 2019

    <p>The American Bankers Association (ABA) appreciates the opportunity to comment on the Exposure Draft Proposed Accounting Standards Update—Financial Instruments—Credit Losses (Topic 326), Derivatives and Hedging (Topic 815), and Leases (Topic 842): Effective Dates.</p>

  • Backgrounder
    CECL Backgrounder and FAQs

    May 01, 2019

    <p>Current Expected Credit Loss Accounting Standard (CECL) Frequently Asked Questions</p>

  • Position Paper
    CECL Implementation Concerns on WARM

    January 24, 2019

    <span style="color: #000000; background-color: #ffffff;">Recommendations on the &ldquo;Q factor analysis process.&rdquo;</span>

  • Comment Letter
    ABA Comments to FASB on Leases

    August 28, 2013

    ABA Comments to FASB re: FASB No. 2013-270 Leases (Topic 842)

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