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February 11, 2016
NAFCU requests 2nd CECL comment period
The Financial Accounting Standards Board should issue an updated credit losses exposure draft and solicit additional public comments, NAFCU President and CEO Dan Berger urged in a letter Thursday to FASB members.
Berger said an updated exposure draft would benefit both credit unions and other stakeholders. "The entire industry deserves every available opportunity to find an appropriate balance between the costs to institutions and the benefits to financial instrument reporting," he wrote.
Berger added that credit unions, as member-owned, not-for-profit cooperatives, should be entirely exempt from the credit losses project. "However, even if the FASB will not consider the special structure of credit unions specifically, at a minimum, the confusion and lack of transparency surrounding the proposal warrants further consideration and delay before finalization," he wrote.
Berger noted the Administrative Procedure Act requires federal agencies to engage in subsequent comment periods if changes are made to a rule that make it no longer a logical outgrowth of the initial proposal. He acknowledged that FASB is a private, nonprofit organization and is not subject to the requirements of the APA but said those requirements could serve as a helpful guide to the board.
Berger also encouraged FASB to work closely with the credit union industry and allow it to voice its concerns as often as possible.
Berger said an updated exposure draft would benefit both credit unions and other stakeholders. "The entire industry deserves every available opportunity to find an appropriate balance between the costs to institutions and the benefits to financial instrument reporting," he wrote.
Berger added that credit unions, as member-owned, not-for-profit cooperatives, should be entirely exempt from the credit losses project. "However, even if the FASB will not consider the special structure of credit unions specifically, at a minimum, the confusion and lack of transparency surrounding the proposal warrants further consideration and delay before finalization," he wrote.
Berger noted the Administrative Procedure Act requires federal agencies to engage in subsequent comment periods if changes are made to a rule that make it no longer a logical outgrowth of the initial proposal. He acknowledged that FASB is a private, nonprofit organization and is not subject to the requirements of the APA but said those requirements could serve as a helpful guide to the board.
Berger also encouraged FASB to work closely with the credit union industry and allow it to voice its concerns as often as possible.
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