FASB's Proposal on Expected Credit Loss Model Released Dec. 20, 2012; Comments Due April 30, 2013

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FASB released on Dec. 20, 2012 its Proposed Accounting Standards Update entitled, Financial Instruments—Credit Losses (Subtopic 825-15). 

FASB's proposed model reflects a move away from the traditional "incurred loss" model toward an "expected loss" model.

The move to more of an "expected loss" model was recommended by many banking and financial institution groups and regulatory groups during and following the financial crisis when some held that such insitutions were underreserved out of fears of crossing GAAP and regulatory lines whose original intent was meant to bar so-called "cookie jar" reserves, or reserves set aside purely for income smoothing.

FASB's proposal attempts to add more flexibility vs. the incurred loss model, by requiring the issuer "to take into account all available information and recognize its current estimate of cash flows not expected to be collected."

The proposal issued by FASB at the end of 2012 differs from the current version of the IASB's anticipated upcoming proposal, described as a 'three bucket approach,' in which "full recognition of an allowance for the expected credit loss would be deferred for financial assets for which a loss event is expected to occur beyond 12 months." On a call with members of the press, FASB Chairman Leslie Seidman described the FASB's decision not to go with the IASB's '3-bucket approach' based on significant feedback from FASB constituents who described the 3-bucket approach as raising operational and practicability issues as well as raising theoretical/economic issues of remaining closer to the current position which some claimed was underreserved.

For more info on FASB's proposal, see FASB's press release , this 3-page FASB in Focus, and FASB's Dec. 2012 podcast featuring Board Member Tom Linsmeier.

Some interestesting commentary has come out on FASB's proposal, including from the usual suspects, (i.e. no-holds-barred commentators such as Tom Selling (what would you expect from a blog called The Accounting Onion ?) , The American Bankers Association, and others.

But the most important comments of all will be YOUR comments on the ED. The comment deadline to FASB is April 30, 2013. Watch for release of the IASB's ED as well (expected to be released in 1Q2013 according to FASB's press release), and feel free to comment on both ED's.

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