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Comment Letter - FASB proposal on targeted improvements to accounting for interest rate risk hedging and net investment hedging


Overview

In our comment letter, we express our continued support for the Board’s ongoing efforts to improve and simplify its guidance on hedge accounting to better portray the economic results of an entity’s risk management activities in its financial statements. We are supportive of the FASB’s proposed amendments to address three discrete hedge accounting issues identified by stakeholders as limitations to the general hedge accounting model. In addition, we suggest that the Board consider providing additional flexibility in the transition approach for certain aspects of the proposal.

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