9.3 Regulator Activities

In April 2023, the federal financial institution regulatory agencies issued an updated interagency policy statement on allowances for credit losses. The policy statement is intended to promote consistency in the interpretation and application of ASC 326 and updates concepts and practices detailed in existing supervisory guidance that remain applicable.

In August 2024, the OCC released the annual update to its Bank Accounting Advisory Series, which “expresses the OCA’s interpretations of accounting topics relevant to national banks and federal savings associations.” The publication includes Topic 12, “Credit Losses Under ASC Topic 326,” which addresses various questions related to ASC 326 (e.g., credit losses on AFS and HTM debt securities, loan modifications, acquired loans, allowances for credit losses, and off-balance-sheet credit exposures).

In November 2019, the SEC staff issued SAB 119 (codified in ASC 326-20-S99). ASC 326-20-S99 addresses the staff’s expectation for management’s policies, procedures, internal controls, and documentation of judgments related to ASC 326. An SEC registrant must apply the guidance in ASC 326-20-S99.

The AICPA’s Audit and Accounting Guide Credit Losses provides preparers and auditors with interpretive guidance related to ASC 326.