Michael Gullette

June 27, 2025

ABA generally supports the specific proposals detailed in the ED, but has significant concerns that need attention if ISSB standards are to provide true baselines for sustainability reporting.

May 29, 2025

The ABA and its members are committed to working constructively with the GRI to develop effective sustainability reporting standards for the financial sector.

March 07, 2025

The American Bankers Association appreciates the opportunity to comment on the Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation: Senate Bills 253 and 261, as amended by SB 219 ("The Solicitation").

February 04, 2025

The American Bankers Association welcomes the opportunity to comment on Measurement of Credit Losses for Accounts Receivable and Contract Assets for Private Companies and Certain Not-for-Profit Entities ("the Exposure Draft," or "ED"). As opposed to codifying a certain practical expedient and policy election for a specific estimation method, we believe addressing the concerns through a FASB staff Q&A document would be more responsive to current practice challenges.

January 27, 2025

The American Bankers Association appreciates the opportunity to comment on the Discussion Paper on Nature Transition Plans. The TNFD DP details draft guidance to help organizations develop and disclose nature transition plans aligning with the Kunming-Montreal Global Biodiversity Framework, agreed upon by governments globally at the December 2022 United Nations Biodiversity Conference.

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.

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.

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.