9.3 Rescission of SAB 121
The SEC’s decision to rescind SAB 121 by issuing SAB 122 will result
                in a number of implications related to entities’ derecognition of the obligations
                and assets previously required by SAB 121. Reporting entities should carefully
                evaluate disclosures about the impact of SAB 122, including those that may be
                required by SAB Topic 11.M (SAB 74) for entities that do not early adopt. For more
                information, see Section 2.19 of Deloitte’s
                Roadmap SEC Comment Letter Considerations, Including
                        Industry Insights. 
            Connecting the Dots
                    The rescission of SAB 121 represents a significant change for entities that
                        were previously within its scope. Given the relative ease of unwinding the
                        safeguarding asset and liability, as well as the complexity of determining
                        whether certain transactions were within the scope of SAB 121, we expect
                        that many entities will elect to effect the rescission early and remove the
                        safeguarding asset and liability.