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Overview
In our comment letter , we support the Board’s objective to provide a uniform accounting approach for purchased financial assets to address investors’ concerns about the complexity of applying the current guidance and the lack of comparability in the accounting for purchased assets with credit deterioration (PCD) and non-PCD assets under ASC 326. However, we recommend revising certain aspects of the proposal to address potential operational issues that could lead to accounting and auditing challenges. Our recommendations include removing credit cards and other revolving credit arrangements from the scope of the guidance, explicitly defining which assets would be in the scope and requiring entities use a prospective transition approach, with an option to apply the guidance on a modified retrospective basis.
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