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Comment Letters

Proposed FASB Accounting Standards Updates

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Fair Value Hedging — Portfolio Layer MethodBusiness Combinations (Topic 805): Accounting for Contract Assets and Contract Liabilities From Contracts With CustomersIntangibles — Goodwill and Other (Topic 350): Accounting Alternative for Evaluating Triggering EventsLeases (Topic 842): Targeted ImprovementsReference Rate Reform (Topic 848) — Scope RefinementFranchisors — Revenue From Contracts With Customers (Subtopic 952-606) — Practical ExpedientCompensation — Stock Compensation (Topic 718): Determining the Current Price of an Underlying Share for Equity-Classified Share-Option AwardsFinancial Services — Insurance (Topic 944): Effective Date and Early ApplicationEffective Dates for Certain EntitiesCodification Improvements to Hedge AccountingCodification ImprovementsSimplifying the Classification of Debt in a Classified Balance Sheet (Current Versus Noncurrent)Facilitation of the Effects of Reference Rate Reform on Financial ReportingAccounting for Convertible Instruments and Contracts in an Entity’s Own EquityFinancial Services — Insurance (Topic 944): Effective DatesFinancial Instruments — Credit Losses (Topic 326), Derivatives and Hedging (Topic 815), and Leases (Topic 842): Effective DatesCodification Improvements to Topic 326, Financial Instruments — Credit LossesSimplifying the Accounting for Income TaxesCodification Amendments in Response to the SEC’s Disclosure Update and Simplification InitiativeCompensation — Stock Compensation (Topic 718) and Revenue From Contracts With Customers (Topic 606): Codification Improvements — Share-Based Consideration Payable to a CustomerChanges to the Disclosure Requirements for Income TaxesTargeted Transition Relief for Topic 326, Financial Instruments — Credit LossesIntangibles — Goodwill and Other (Topic 350), Business Combinations (Topic 805), and Not-for-Profit Entities (Topic 958): Extending the Private Company Accounting Alternatives on Goodwill and Certain Identifiable Intangible Assets to Not-for-Profit Entities Extending the Private Company Accounting Alternatives on Goodwill and Certain Identifiable Intangible Assets to Not-for-Profit EntitiesCodification Improvements for LessorsCodification Improvements — Financial InstrumentsCodification Improvements to Topic 326, Financial Instruments — Credit LossesLeases (Topic 842): Narrow-Scope Improvements for LessorsCollaborative Arrangements (Topic 808): Targeted ImprovementsDerivatives and Hedging (Topic 815): Inclusion of the Overnight Index Swap (OIS) Rate Based on the Secured Overnight Financing Rate (SOFR) as a Benchmark Interest Rate for Hedge Accounting PurposesLeases (Topic 842): Targeted ImprovementsReclassification of Certain Tax Effects From Accumulated Other Comprehensive IncomeCodification ImprovementsConsolidation (Topic 812): ReorganizationTechnical Corrections and Improvements to Recently Issued Standards — Accounting Standards Update No. 2016-02, Leases (Topic 842)Technical Corrections and Improvements to Recently Issued Standards (Subtopic 825-10)Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made (Topic 958)Land Easement Practical Expedient for Transition to Topic 842 Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for Variable Interest EntitiesTechnical Corrections and Improvements to Topic 995, U.S. Steamship EntitiesTechnical Corrections and Improvements to Topic 942, Financial Services — Depository and Lending: Elimination of Certain Guidance for Bad Debt Reserves of Savings and LoansImprovements to Nonemployee Share-Based Payment AccountingSimplifying the Classification of Debt in a Classified Balance Sheet (Current Versus Noncurrent)Changes to the Disclosure Requirements for InventoryDistinguishing Liabilities From Equity (Topic 480): I. Accounting for Certain Financial Instruments With Down Round Features and II. Replacement of the Indefinite Deferral for Mandatorily Redeemable Financial Instruments of Certain Nonpublic Entities and Certain Mandatorily Redeemable Noncontrolling Interests With a Scope ExceptionScope of Modification AccountingTargeted Improvements to the Accounting for Long-Duration ContractsPremium Amortization on Purchased Callable Debt SecuritiesTargeted Improvements to Accounting for Hedging ActivitiesTechnical Corrections and Improvements to Update No. 2014-09, Revenue From Contracts With Customers (Topic 606) — Additional CorrectionsClarifying When a Not-for-Profit Entity That Is a General Partner Should Consolidate a For-Profit Limited Partnership or Similar EntityChanges to the Disclosure Requirements for Income TaxesClarifying the Scope of Asset Derecognition Guidance and Accounting for Partial Sales of Nonfinancial AssetsInterests Held Through Related Parties That Are Under Common ControlSimplifying the Accounting for Goodwill ImpairmentTechnical Corrections and Improvements to Update No. 2014-09, Revenue From Contracts With Customers (Topic 606)Technical Corrections and ImprovementsChanges to the Disclosure Requirements for Defined Benefit PlansImproving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit CostDisclosure Framework — Changes to the Disclosure Requirements for Fair Value MeasurementDisclosures by Business Entities About Government AssistanceClarifying the Definition of a BusinessProposed Amendments to ASC 235 and the Conceptual FrameworkNarrow-Scope Improvements and Practical ExpedientsPrincipal Versus Agent Considerations (Reporting Revenue Gross Versus Net)Presentation of Financial Statements of Not-for-Profit EntitiesImprovements to Employee Share-Based Payment AccountingSimplifying the Equity Method of AccountingSimplifying the Accounting for Measurement-Period AdjustmentsIdentifying Performance Obligations and LicensingIntra-Entity Asset TransfersBalance Sheet Classification of Deferred TaxesRevenue From Contracts With Customers (Topic 606): Deferral of the Effective DateDisclosures About Hybrid Financial Instruments With Bifurcated Embedded DerivativesDisclosures About Investments in Other Investment CompaniesPractical Expedient for the Measurement Date of an Employer's Defined Benefit Obligation and Plan AssetsSimplifying the Presentation of Debt Issuance CostTechnical Corrections and ImprovementsCustomer’s Accounting for Fees Paid in a Cloud Computing ArrangementSimplifying Income Statement Presentation by Eliminating the Concept of Extraordinary ItemsSimplifying the Measurement of InventoryDevelopment Stage Entities (Topic 915): Elimination of Certain Financial Reporting RequirementsInsurance ContractsApplying Variable Interest Entity Guidance to Common Control Leasing ArrangementsDisclosure of Uncertainties About an Entity’s Going Concern PresumptionDefinition of a Public Business EntityLeases (Topic 842)Reporting Discontinued OperationsAccounting for Identifiable Intangible Assets in a Business CombinationAccounting for GoodwillAccounting for Certain Receive-Variable, Pay-Fixed Interest Rate SwapsTechnical Corrections and Improvements Related to Glossary TermsFinancial Instruments — Credit LossesDeferral of the Effective Date of Certain Disclosures for Nonpublic Employee Benefit Plans in Update No. 2011-04Recognition and Measurement of Financial Assets and Financial LiabilitiesEffective Control for Transfers With Forward Agreements to Repurchase Assets and Accounting for Repurchase FinancingsClarifying the Scope and Applicability of a Particular Disclosure to Nonpublic EntitiesClarifying the Scope of Disclosures About Offsetting Assets and LiabilitiesPresentation of Items Reclassified Out of Accumulated Other Comprehensive IncomeThe Liquidation Basis of AccountingDisclosures About Liquidity Risk and Interest Rate RiskTesting Indefinite-Lived Intangible Assets for ImpairmentRevenue Recognition (Topic 605), Revenue From Contracts With CustomersFinancial Services — Investment Companies (Topic 946): Amendments to the Scope, Measurement, and Disclosure RequirementsReal Estate — Investment Property Entities (Topic 973)Consolidations (Topic 810), Principal Versus Agent AnalysisTechnical CorrectionsDeferral of the Effective Date for Amendments to the Presentation of Reclassifications of Items Out of Accumulated Other Comprehensive Income in Accounting Standards Update No. 2011-05Testing Goodwill for ImpairmentReconsideration of Effective Control for Repurchase AgreementsDeferral of the Effective Date of Disclosures About Troubled Debt Restructurings in Update No. 2010-20Clarifications to Accounting for Troubled Debt Restructurings by CreditorsDisclosure About an Employer’s Participation in a Multiemployer PlanRevenue From Contracts With CustomersComprehensive IncomeDisclosure of Certain Loss ContingenciesAmendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities Subsequent Events (Topic 855) — Amendments to Certain Recognition and Disclosure RequirementsAmendments to Statement 167 for Certain Investment FundsScope Exception Related to Embedded Credit DerivativesOil and Gas Reserve Estimation and DisclosuresImproving Disclosures About Fair Value MeasurementsFASB Exposure Draft of a Proposed Accounting Standards Update of Topic 810