Among the over 140 comment letters
filed on FASB and the IASB's January, 2011 proposals on offsetting (netting
) of balance sheet assets and liabilities, evidencing the international scope of constituents sharing their views with the boards on this proposal, are comment letters from the Belgian Accounting Standards Board (BASB
), Dutch Accounting Standards Board (DASB
), Korea Accounting Standards Board (KASB
), among other national accounting boards.
Topics addressed in comment letters include the definition of netting 'simulatenously' in different time zones, netting of multiple contracts/books of business with particular counterparties through clearinghouses vs. individual contracts directly via the counterparties, issues relating to legal terminology and contracts, and the extent of disclosures required on a cost-benefit basis.
Comment letters were also filed by preparer organizations including FEI's Committee on Corporate Reporting
, FEI Canada's Committee on Corporate Reporting
, and IMA's Financial Reporting Committee. A number of companies filed individual comment letters as well.
Organizations filing comment letters on behalf of the audit profession include those filed by the AICPA's Financial Reporting Executive Committee
, and separate letters filed by the largest accounting firms as well as midsize/regional firms.
Letters were also filed by industry specific groups that would be keenly impacted by changes to the offsetting (netting) rules, particularly in the financial services industry, such as the American Banker's Association
, the Securities Industry and Financial Markets' Association's Dealer Accounting Committee
, and SIFMA's Funding Executive Committee
. Other international banking organizations and individual financial services companies filed comment letters as well.
Interestingly, the Federal Housing Finance Agency (FHFA - regulator of Fannie Mae and Freddie Mac) filed a one page FHFA comment letter
supporting the proposals, while the 12 Federal Home Loan Banks filed a four-page FHLB comment letter
objecting to various aspects of the proposals.
In addition, IOSCO
(and other national and international regulatory organizations) added their views to the mix.
Refer to the exposure drafts and the comment letter page linked above for further details on the offsetting proposal and constituent views.ROUNDTABLES THIS WEEK
The first of 3 public roundtable discusions
jointly sponsored by the IASB and FASB on the offsetting (netting) proposal is slated to take place tomorrow May 3 at the IASB in London
. Additional roundtables will be held May 6 in Singapore
, and next Monday May 9 at FASB's offices in Norwalk, CT
. The roundtables will be available by public webcast; registration is required.