Michael Gullette

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 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.

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.

May 01, 2019

Current Expected Credit Loss Accounting Standard (CECL) Frequently Asked Questions

January 24, 2019

Recommendations on the 'Q factor analysis process.'

August 28, 2013

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