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.
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.