FASB Invitation to Comment on Technical Agenda

Published on:
September 21, 2021
Submitted to:
FASB
Submitted by:
SIFMA
File Number:
File Reference No. 2021-004

Summary

SIFMA provided comments to the Financial Accounting Standards Board (FASB) on their technical agenda. Our Committee members have significant expertise in the accounting matters faced by a wide range of financial institutions, and are happy to share our practical experience with the FASB Staff to help drive future standard-setting.

Excerpt

September 21, 2021

VIA ELECTRONIC SUBMISSION

Ms. Hillary Salo

Technical Director, FASB

401 Merritt 7

PO Box 5116

Norwalk, CT 06856-5116

Re: File Reference No. 2021-004. Invitation to Comment: Agenda Consultation

Dear Ms. Salo:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to respond to the invitation to comment (“ITC”) on the Financial Accounting Standards Board’s (“FASB’s” or “Board’s”) technical agenda. Our Committee members have significant expertise in the accounting matters faced by a wide range of financial institutions, and are happy to share our practical experience with the FASB Staff to help drive future standard-setting that focuses on matters where: (1) there is a pervasive need for improvement with identifiable scope; (2) solutions are technically feasible; and (3) the expected benefits exceed the expected costs associated with the change.

Detailed responses to the specific questions raised in the invitation are included in Appendix I, but we would like to highlight the following key items for specific consideration:

– Hedge Accounting – Phase 2: While significant progress has been made with regard to the hedge accounting guidance, we believe there remains a number of key items that require additional consideration, many of which being particularly pressing (see our responses to Question 5 for more information). As a result, we believe this should be a top priority for the Board.

– Digital assets: Given the growth in this asset class, as well as increased focus by various regulators, we believe the Board should prioritize a project that addresses both classification (i.e., as a non-intangible asset) and measurement (i.e., availability of the fair value option).

– Environmental, social and governance (“ESG”) related transactions: Although generally not yet material for our member firms, we expect this activity (e.g., loans or deposits with interest rates that vary based on the counterparty’s performance against certain defined ESG-related targets) to increase significantly in the short-term and, therefore, believe a project aimed at mitigating the need for bifurcation of embedded derivative and fair value measurement requirement should be a priority of the Board.

– Definition of a derivative: In addition to addressing the item immediately above, we believe the Board should also prioritize clarifying the accounting for amendments to derivatives, particularly as it relates to defining the “initial investment.” This is an area that creates meaningful complexity in practice.

Continue Reading

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.