June 1, 2023

VIA ELECTRONIC SUBMISSION

Ms. Hillary Salo
Technical Director, FASB
801 Main Avenue
PO Box 5116
Norwalk, CT 06856-5116

Re: File Reference No. 2023-ED200, Intangibles – Goodwill and Other – Crypto Assets (Subtopic 350-60), Accounting for and Disclosure of Crypto Assets

Dear Ms. Salo,

SIFMA1 appreciates the opportunity to comment on the proposed Accounting Standard Update “Intangibles – Goodwill and Other – Crypto Assets (Subtopic 350-60), Accounting for and Disclosure of Crypto Assets” (“proposed ASU”). In SIFMA’s response2 to the invitation to comment on the Financial Accounting Standards Board’s (the “Board”) technical agenda (“2021 ITC”), we encouraged the Board to prioritize a project that would address the classification and measurement of crypto assets and, therefore, are pleased the Board subsequently elected to do so and has made significant progress in a relatively short period of time.

I. Executive Summary

SIMFA agrees with the Board’s proposal that the crypto assets described in the proposed ASU should be measured at fair value with changes recognized in net income. Under the current framework, absent the application of industry-specific guidance, an entity is only permitted to mark the carrying value of these types of crypto assets below their initial cost, with no ability to mark up, including for previously recorded losses. As a result, the volatility and full range of crypto asset price movements is not being captured directly in the financial statements, and entities may be carrying such assets at amounts significantly below the levels at which they could be readily converted to cash. SIFMA, therefore, believes fair value measurement is more appropriate and transparent to users of the financial statements.

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 1 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. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

2 See generally SIFMA Comment Letter to FASB on Invitation to Comment on Technical Agenda (Sept. 21, 2021), https://www.sifma.org/resources/submissions/invitation-to-comment-fasb-agenda-consultation/.