May 30, 2025

Submitted electronically to: [email protected]

Mr. Jackson M. Day
Technical Director
Financial Accounting Standards Board
801 Main Avenue
P.O. Box 5116
Norwalk, CT, 06820

Re: File Reference No. 2024-ITC200

Dear Mr. Day,

The Securities Industry and Financial Markets Association (“SIFMA”)¹ appreciates the opportunity to comment on the Invitation to Comment— Recognition of Intangibles (the “ITC”). SIFMA supports the Financial Accounting Standards Board’s (the “FASB” or “Board”) efforts to solicit stakeholder feedback on its future standard setting agenda, including on whether the Board should pursue standard setting on intangibles, whether recognized as assets in the financial statements, or not recognized as assets. Our comments on intangibles exclude software, in light of the final ASU to be issued later this year on this topic.

SIFMA believes there is not a pervasive need to improve GAAP related to the accounting for or disclosure of intangibles. The current model is well understood, and the potential changes to the model would not represent an improvement to the usefulness of the financial reporting for intangibles. Further, recognizing internally generated intangibles would require additional complex judgments and result in Level 3 valuations that would likely be of limited benefit to users of financial statements.

Attached please find an appendix that includes SIFMA’s responses to the Questions for Respondents. Questions not relevant to SIFMA members are excluded.

Thank you for the opportunity to comment. Should you have any questions or require further information concerning any of the matters discussed in this letter, please do not hesitate to contact the undersigned.

Sincerely,

Laurin Smith Kevin A. Zambrowicz
Managing Director, JPMorganChase
Chair, SIFMA Accounting Committee
[email protected]

Kevin A. Zambrowicz
Deputy General Counsel
SIFMA

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 one million employees, we advocate on 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). [↩]