The American Institute of Certified Public Accountants’ Financial Reporting Executive Committee submitted a comment letter, dated March 30, 2011, to the Financial Accounting Standards Boards on its supplementary document, “Accounting for Financial Instruments and Revisions to the Accounting for Derivatives Instruments and Hedging Activities-Impairment.”
We do not support the full life expected loss model that was originally proposed. We believe that the incurred loss model for recognition of credit impairment should be retained since we believe losses should not be recognized until there is a triggering event.
FinREC supports the efforts of FASB and the International Accounting Standards Board to achieve convergence. However, it believes more time must be given to adequately study the issues and provide further detailed and meaningful commentary on this supplementary document. Comments discuss that the proposed model deals with a limited scope when it comes to addressing the recognition of impairment in open portfolios and does not address related issues such as debt securities and troubled debt restructurings single loans.
A copy of the letter is available at Accounting for Financial Instruments and Revisions to Accounting for Derivatives Instruments and Hedging Activities-Impairment. If you would like to speak to Dan Noll, CPA, AICPA director of accounting standards, please contact Mitchell Slepian, manager, media relations, 212.596.6177 or firstname.lastname@example.org.