The Bond Market Association (TBMA)* provides supplemental comments to the Financial Accounting Standards Board (FASB) on the guidance in FASB Statement 140, specifically Paragraph 94, regarding the method of accounting for “borrow versus pledge” transactions.  TBMA raised substantive points raised in their earlier comment letter and now expresses their members’ continued high level of concern both about the substantive impact of this guidance and the lack of due process afforded with respect to its formulation.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.