Date: January 13, 2017
Issue: Accounting; International
To: Basel Committee on Banking Supervision
Filing Type: Comment Letter
Description: CCMC submitted comments regarding the Consultative Document and related Discussion Paper on Regulatory Treatment of Accounting Provisions —Interim Approach and Transitional Arrangements. The Consultative Documents recognize the introduction of new accounting standards by the International Accounting Standards Board and the United States Financial Accounting Standards Board that will require the use of expected credit loss (“ECL”) models instead of incurred loss models. CCMC urges the Committee not to move forward with any changes in regulatory treatment until banks have had a chance in the United States and elsewhere to see how ECL accounting and other expected credit loss metrics are actually working.