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Comment Letter - FASB proposal on TDRs for creditors and vintage disclosures


In our comment letter, we support the FASB’s proposal to eliminate the troubled debt restructuring (TDR) recognition and measurement guidance for creditors because it does not provide decision-useful information about entities that apply ASC 326. We also support the FASB’s proposal to require enhanced disclosures about certain modifications, though we noted aspects of the proposal that we believe could be clarified further. In addition, we support the proposal to require public entities to disclose current-period gross write-offs by year of origination for financing receivables and net investments in leases in the vintage disclosures required by ASC 326.

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