SAB 121 Deferral Request

Published on:
May 27, 2022
Submitted to:
SEC
Submitted by:
SIFMA and ABA

Summary

SIFMA and the American Bankers Association (ABA)  provided comments to the Securities and Exchange Commission (SEC) on the various accounting considerations regarding crypto-assets. Given the unique characteristics of many crypto-assets, we believe that in certain cases the existing accounting

guidance being applied to crypto-assets does not necessarily provide decision-useful information to users of the financial statements. Accordingly, in our responses to the Financial Accounting Standards Board’s (FASB) agenda consultation last year, we asked the Board to add a project to its technical agenda to address the classification and measurement of digital assets, and were pleased that earlier this month the Board voted to do so.

Excerpt

May 27, 2022

VIA ELECTRONIC SUBMISSION

Paul Munter

Acting Chief Accountant

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re: Request for Deferral of Effective Date of Staff Accounting Bulletin No. 121 “Accounting for Obligations to Safeguard Crypto-Assets an Entity Holds for its Platform Users” (“SAB 121”)

Dear Mr. Munter:

The Securities Industry and Financial Markets Association (“SIFMA”)1 and the American Bankers Association (“ABA”)2 appreciate the focus of the Securities and Exchange Commission’s (“SEC”) Office of the Chief Accountant and Division of Corporation Finance (collectively, the “Staff”) on the various accounting considerations regarding crypto-assets. Given the unique characteristics of many crypto-assets, we believe that in certain cases the existing accounting guidance being applied to crypto-assets does not necessarily provide decision-useful information to users of the financial statements. Accordingly, in our responses3 to the Financial Accounting Standards Board’s (“FASB” or the “Board”) agenda consultation last year, we asked the Board to add a project to its technical agenda to address the classification and measurement of digital assets, and were pleased that earlier this month the Board voted to do so.

Continue Reading

1 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly one million employees, we advocate for legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. With offices in New Yorkand Washington, D.C., SIFMA is the U.S. regional member of the Global Financial Markets Association (GFMA).

2 The American Bankers Association is the voice of the nation’s $24.0 trillion banking industry, which is composed of small, regional, and large banks that together employ more than 2 million people, safeguard $19.9 trillion in deposits and extend $11.4 trillion in loans.

3 See SIFMA and ABA Comment Letters on FASB Invitation to Comment on Technical Agenda, File Reference No. 2021-004, SIFMA letter available here and ABA letter available here.

Details

Download

More Content

  • Letters
    Oct 22, 2026

    Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

    SIFMA supports modernizing retirement plan rollovers through standardized electronic processes, fraud safeguards and appropriate implementation timelines.
  • Amicus Briefs
    Oct 21, 2026

    In re USD LIBOR Litigation

  • Letters
    Oct 20, 2026

    SEC’s Proposed Rule Regulation Crypto Assets

    SIFMA and SIFMA AMG provide recommendations to the SEC on its proposed crypto asset regulation, addressing regulatory clarity, implementation and investor protection.

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