The Securities Industry Association (SIA)* provides comments to the Financial Accounting Standards Board (FASB) relating to the consolidation of variable interest entities, File Ref. No. 1082-300. SIA disagrees with the issuance of the draft. A delay would provide time for a comprehensive review of FIN 46 that could lead to the issuance of a more complete, logical, and user-friendly standard. A delay would allow the FASB to address complex matters such as expected loss calculations in a subsequently issued FASB staff position.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.