9.1 Overview
ASC 326 has been effective for all calendar-year entities since 2024. In addition,
since the issuance of ASC 326, the FASB has amended the guidance by releasing
various ASUs that are now effective for all entities. As part of its
post-implementation review process, the FASB is continuing to evaluate whether ASC
326 is achieving its objective by considering stakeholder input and feedback, along
with other research, to determine whether any improvements should be made. The Board
has issued a proposed ASU that would change the scope of the PCD “gross up”
model (see Section 9.2.1) as well as a proposed ASU that introduces a practical expedient and
accounting policy election for private companies and certain not-for-profit entities
(see Section 9.2.2).
Further, the SEC and various banking regulators, such as the Federal Reserve Board,
OCC, FDIC, National Credit Union Administration, and Federal Housing Finance Agency,
were involved in the standard-setting process (e.g., through their involvement in
TRG meetings) and have continued to provide guidance on the application of ASC 326.
Stakeholders should continue to monitor activity at the FASB, SEC, and other
standard setters or regulators for any relevant developments or interpretations.