Michael Gullette

March 13, 2024

We express significant concerns related to key elements of the CD and urge the Committee to work with banking institutions to assess and then propose alternative disclosures that are meaningful within the context of the stated Pillar 3 objectives and overall BCBS framework.

November 28, 2023

ABA supports efforts to develop an overarching auditing and assurance standard that addresses sustainability matters and our comments are meant to address some of the specific questions posed in the stakeholder survey.

September 26, 2023

ABA believes that more discussion among stakeholders will be needed before an effective and generally accepted taxonomy can be finalized.

August 19, 2023

Comments on the ISSB's Request for Information - Consultation on Agenda Priorities.

March 16, 2023

The American Bankers Association is pleased at the opportunity to comment on Notice 2023-7: Initial Guidance Regarding the Application of the Corporate Alternative Minimum Tax under Sections 55, 56A, and 59 of the Internal Revenue Code (Notice). The Notice announces the intent of the Department of the Treasury and the Internal Revenue Service (IRS) to issue proposed regulations addressing the application of the new corporate alternative minimum tax (CAMT), which was enacted through the Inflation Reduction Act of 2022 (IRA).

March 03, 2023

ABA's response to the IRS's notice announcing the intent of the Department of the Treasury and the Internal Revenue Service (IRS) to issue proposed regulations addressing the application of the new excise tax on repurchases of corporate stock under §4501 of the Internal Revenue Code, which was enacted through the Inflation Reduction Act of 2022 (IRA).

December 21, 2022

ABA comment letter to joint agencies regarding the FAR proposal requiring certain Federal contractors to disclose their greenhouse gas emissions and climate-related financial risks, as well as set science-based targets to reduce their greenhouse gas emissions.

August 18, 2022

CECL has been adopted by many organizations and for many more, the countdown to adoption has begun. But what defines a successful CECL journey? How do you know if results make sense? And what can you use CECL insights for? In our world of economic volatility, these are the questions that keep Risk and Finance executives up at night. In this podcast, we address these question. Speakers: Theresa Meawad, Head of Solutions Consulting and Thought Leadership, SS&C EVOLV Michael L. Gullette, Senior Vice President, Tax and Accounting, ABA

July 28, 2022

Comment on the Exposure Drafts IFRS S1 General Requirements for Disclosure of Sustainability-related Information and IFRS S2 Climate-related Disclosures.

July 20, 2022

The American Bankers Association (ABA) appreciates the opportunity to comment on the Strategic Plan Draft (May 2022) of the Financial Accounting Foundation (FAF), which provides oversight to the Financial Accounting Standards Board (FASB), and the Governmental Accounting Standards Board (GASB).

June 17, 2022

The American Bankers Association appreciates this opportunity to respond to the Proposed Rule: The Enhancement and Standardization of Climate-Related Disclosures for Investors (Proposal), which would be applicable to all public companies.

March 31, 2022

The new FASB standard to end TDR accounting for CECL adopters announced today is a major step in the right direction. Accounting for troubled debt restructurings is not only operationally onerous and often confusing to investors, it also is unnecessary under CECL, which requires the lifetime credit loss measurement.

June 11, 2021

RE: Climate Change Disclosure Request for Input

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).

December 22, 2020

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

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.

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.

September 13, 2019

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.

September 13, 2019

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.

September 13, 2019

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.