The Accounting Committee discusses and examines current market practices as well as developments arising from accounting standard setters and the international harmonization of accounting standards. The Committee works with the International Accounting Standards Board (IASB), the Financial Accounting Standards Board (FASB), and other national accounting standard setters, along with the Securities and Exchange Commission (SEC) in the US, the Commission of the European Union, and the UK's Department of Trade and Industry ( DTI ). The Committee has considered a wide range of issues including hedge accounting, disclosure practices, fair value measurement, and international harmonization.

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ACCOUNTING ISSUES

SUBMISSION DATE ADDRESSED TO TOPIC SUMMARY
3/9/2011
IASB (International Accounting Standards Board) ISDA's Comment Letter on the IASB's Exposure Draft ED/2010/13 - Hedge Accounting
1/31/2011
ISDA Members IASB/FASB - Exposure Draft on Offsetting Financial Assets and Financial Liabilities
1/31/2011
IASB (International Accounting Standards Board) ISDA's Comment letter on te IASB's Request for Views on "Effective Dates and Transition Methods”
11/26/2010
IASB (International Accounting Standards Board)

ISDA's comment letter on the IASB's exposure draft: "ED/2010/8: Insurance Contracts"

11/15/2010
The IASB and the FASB Offsetting of Derivatives Assets and Liabilities
9/7/2010

FASB (Financial Accounting Standards Board)

ISDA's Comment letter to the FASB on 'Proposed Accounting Standards Update: Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRSs' File Reference Number 1830-100

9/7/2010
IASB (International Accounting Standards Board) ISDA's Comment letter on the IASB's Exposure Draft on “Measurement Uncertainty Analysis Disclosure for Fair Value Measurements (ED/2010/7)
9/1/2010
FASB (Financial Accounting Standards Board) ISDA's Comment letter to the FASB on ‘Proposed Accounting Standards Update: Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities’ File Reference Number 1810-100
7/15/2010
The Boards Issues relating to derivatives netting under FIN 39
7/13/2010
IASB (International Accounting Standards Board) ISDA's Comment letter on the IASB's Exposure Draft  on “Fair Value Option for Financial Liabilities”
4/14/2010
European Commission Internal Markets and Services ISDA letter to the European Commission  on IFRS 9Classification and Measurement
11/30/2009

IASC Foundation

“Part 2 of the Constitution Review / Proposal for Enhanced Public Accountability”

10/9/2009
Russell Golden, FASB Proposed Accounting Standards Update to Topic 820, Improving Disclosures about Fair Value Measurements
9/28/2009
IASB (International Accounting Standards Board) ISDA's Comment letter on the IASB's Exposure Draft on 'Fair Value Measurement"
9/14/2009
IASB (International Accounting Standards Board) ISDA's Comment letter on the IASB's Exposure Draft  on “Financial Instruments: Classification and Measurement"
9/3/2009
European Commission

European Commission second Stakeholders’ meeting in Brussels on IAS 39

9/1/2009
IASB (International Accounting Standards Board)

ISDA's Comment letter on IASB's Discussion Paper on " Credit Risk in Liability Measurement"

7/8/2009
Russell Golden, FASB Proposed FASB Staff Position FAS 157-g, Estimating the Fair Value of Investments in Investment Companies That Have Calculated Net Asset Value per Share in Accordance with the AICPA Audit and Accounting Guide, Investment
6/4/2009
IASB (International Accounting Standards Board)

ISDA's letter to the IASB on the IAS 39 replacement project

6/1/2009
Russell Golden, FASB

Proposed FASB Staff Position FAS 157-f, Measuring Liabilities under FASB Statement No. 157

4/17/2009
IASB (International Accounting Standards Board)

ISDA's Comment letter on "IASB's request for views on the FASB's FSP FAS 157-4"

4/17/2009
IASB (International Accounting Standards Board)

ISDA's Comment letter on "IASB's request for views on the FASB's FSP FAS 115-2 and 124-2”

4/2/2009
FACG (Financial Crisis Advisory Group) ISDA's Comment letter on “Financial Crisis Advisory Group (FCAG) Written Submissions from Constituents”
3/31/2009
IASC Foundation

ISDA's Comment letter on “IASC Foundation Review of the Constitution: Identifying Issues for Part 2 of the Review”

3/27/2009
Russell Golden, FASB ISDA Comments on Proposed FASB Staff Position FAS 115-a, FAS 124-a, and EITF 99-20-b, Recognition and Presentation of Other-Than-Temporary Impairments
3/27/2009
Russell Golden, FASB ISDA Comments on Proposed FASB Staff Position FAS 157-e, Determining Whether a Market Is Not Active and a Transaction Is Not Distressed
2/13/2009

Russell Golden, FASB

ISDA Comments on Proposed Issue C22, Exception Related to Embedded Credit Derivatives
2/6/2009
Basel Committee on Banking Supervision Supervisory Guidance for Assessing Banks’ Financial Instrument Fair Value Practices
1/20/2009
IASB (International Accounting Standards Board) ISDA's Comment Letter to IASB's Exposure Draft "Embedded Derivatives -- Amendments to IFRS 7 and IAS 39"
1/15/2009
IASB (International Accounting Standards Board) ISDA's Comment letter on IASB's Exposure Draft on "Investments in Debt Instruments - Proposed Amendments to IRFS 7"
10/23/2008

The European Commission, Brussels, Belgium

ISDA's Comment letter on the European Union Draft letter to the IASB on IAS 39 reclassifications and the credit crisis accounting issues
10/9/2008
Russell Golden, FASB ISDA’s comment letter in response to Financial Accounting Standards Board’s (the “FASB”) proposed FASB Staff Position FAS 157-d, Determining the Fair Value of a Financial Asset in a Market That Is Not Active
9/19/2008
IASB (International Accounting Standards Board)

ISDA's Comment letter on IASB's Discussion Paper on “Reducing Complexity in Reporting Financial Instruments”

9/19/2008
IASC Foundation

ISDA's Comment letter on IASC Foundation's Discussion Paper on “Public Accountability and the Composition of the IASB: Proposals for change”

9/12/2008

M. Fernando Restoy, Chairman, CESR Fin, 11-13 avenue de Friedland – 75008, Paris, France

Draft CESR Consultation: “Fair Value Measurement and related disclosures of financial instruments in illiquid markets”

9/5/2008
IASB (International Accounting Standards Board) ISDA's Comment letter on IASB's Discussion Paper on “Financial Instruments with Characteristics of Equity”
8/15/2008
Russell Golden, FASB

ISDA’s comment letter regarding Financial Accounting Standards Board’s (the “FASB”) Exposure Draft of Proposed Statement of Financial Accounting Standards, Accounting for Hedging Activities, an amendment of FASB Statement No. 133 File Reference: 1590-100

5/30/2008 Mr Golden 1550-100, Preliminary Views on Financial Instruments with Characteristics of Equity
2/18/2008 Russell Golden, FASB Proposed FASB Staff Position FAS 157-c, Measuring Liabilities under FASB Statement No. 157
1/11/2008 Rachel Knubley, International Accounting Standards Board ISDA response to the IASB’s proposed amendments to IAS 39 regarding exposures qualifying for hedge accounting
11/13/2007 Nancy M. Morris, Securities and Exchange Commission ISDA and the Dealer Accounting Committee of the SIFMA comments with respect to the Securities and Exchange Commission’s concept release on allowing U.S. issuers the option to prepare financial statements in accordance with IFRS, as published by the IASB
10/19/2007 Tricia O'Malley, IFRIC Coordinator, IASB ISDA letter supporting IFRIC Draft Interpretation D22, Hedges of a Net Investment in a Foreign Operation
10/15/2007 Russell Golden, FASB ISDA’s comment letter regarding the proposed FASB Staff Position APB 14-a, Accounting for Convertible Debt Instruments That May Be Settled in Cash upon Conversion (Including Partial Cash Settlement)
9/24/2007 Securities and Exchange Commission ISDA supports the SEC’s proposal to allow a foreign private issuer to file financial statements prepared in accordance with IFRS as published by the IASB without reconciliation to US GAAP
9/21/2007 Russell Golden, FASB ISDA’s comment letter regarding the FASB’s proposed Statement No. 133 Implementation Issue E23, “Issues Involving the Application of the Shortcut Method under Paragraph 68”
7/02/2007 Tricia O'Malley, IFRIC ISDA letter re IFRIC Tentative Agenda Decision: IAS 39 Financial Instruments: Recognition and Measurement - Hedging future cash flows with pruchased options
5/4/2007 Jon Nelson, IASB (International Accounting Standards Board) ISDA comment letter on the IASB’s Discussion Paper on Fair Value Measurement and SFAS 157
4/13/2007 Mr. Paul Beswick, FASB Practice Fellow, FASB ISDA’s comments with respect to the Financial Accounting Standards Board’s Invitation to Comment on Valuation Guidance for Financial Reporting
3/02/2007 Mr. Lawrence Smith, Technical Director, FASB ISDA’s comments with respect to the Financial Accounting Standards Board’s proposed Statement of Financial Accounting Standards, Disclosures about Derivative Instruments and Hedging Activities
2/27/2007 Mr. Lawrence Smith, EITF Chair ISDA’s views with regards to the EITF Issue No. 07-B, “Accounting for Convertible Instruments that Require or Permit Partial Cash Settlement upon Conversion” (“Issue 07-B”)
12/08/2006
Mr. Larry Smith
Director – Technical Application and Implementation Activities
FASB
ISDA and ASF are pleased to offer the following comments in response to the Financial Accounting Standards Board’s (“FASB”) Proposed Statement 133 Implementation Issue No. B40, Embedded Derivatives: Application of Paragraph 13(b) to Securitized Interests in Prepayable Financial Assets, (“Proposed Issue B40”).
11/03/2006 IASB (International Accounting Standards Board) ISDA letter on the IASB and FASB Joint Conceptual Framework for Financial Reporting Preliminary views paper
10/23/2006 IASB (International Accounting Standards Board) ISDA response to proposed amendments to IAS 32
09/18/2006 Sir David Tweedie, Chairman of IASB Industry comments on the importance of a global fair value measurement standard
05/19/2006 Peter Martin, Canadian Accounting Standards Board ISDA response to the Discussion Paper on Measurement Bases for Financial Accounting - Measurement on Initial Recognition
04/05/2006 Mr. Larry Smith
Director – Technical Application and Implementation Activities
FASB
ISDA, SIA, ASF and TBMA are pleased to offer the following comments in response to the FASB’s Proposed Statement of Financial Standards, The Fair Value Option for Financial Assets and Financial Liabilities (the “Exposure Draft”)
11/30/2005 Mr. Lawrence W. Smith
Director—Technical Application and Implementation Activities
FASB
Comment Letter on FIN 46(R) FASB Staff Position submitted to FASB on behalf of a joint industry working group consisting of ISDA ASF, TBMA, CMSA, and SIA
11/21/2005 Ms. Suzanne Q. Bielstein
Director – Major Projects and Technical Activities
Mr. Lawrence W. Smith
Director – Technical Application and Implementation Activities
Comments from ISDA, SIA and ASF in response to FASB's Working Draft of SFAS No. 15X, and proposed FSP No. FAS 133-a
10/31/2005 Prof Dr Arnold Schilder, Chairman of the Accounting Task Force, Basel Committee ISDA Letter on the Consultative Document “Supervisory guidance on the use of the fair value option by banks under International Financial Reporting Standards” published in July 2005
10/28/2005 Alan Texeira, Senior Project Manager, IASB ISDA Response Letter to IASB’s Exposure Draft of proposed changes to IFRS 3: Business Combinations
10/10/2005 Mr. Lawrence Smith
Director – Technical Application and Implementation Activities
Financial Accounting Standards Board
Comments from ISDA regarding Accounting for Certain Hybrid Financial Instruments an amendment of FASB Statements No. 133 and 140
09/22/2005 Linda MacDonald
Financial Accounting Standards Board
Comments from ISDA, SIA and ASF on Fair Value Measurements and Dealer Profit
05/31/2005 IASB ISDA Letter to IASB on IFRIC Draft Interpretation: Reassessment of Embedded Derivatives
05/27/2005 Svetlana Boysen, Project Manager, EFRAG ISDA Letter to EFRAG on IFRIC Draft Interpretation: Reassessment of Embedded Derivatives
04/08/2005 Andrea Pryde, IASB ISDA Letter to IASB on ED-7 "Financial Instruments: Disclosures" and new proposals around "day 1" profits
03/16/2005 ISDA European Accounting Committee ISDA Summary of the IASB Fair Value Option Public Roundtable, March 16, 2005
01/24/2005 Joint ISDA Committee Meeting held on 24th January, 2005 (NEW YORK)

Practical Impact of New Accounting Rules - International Financial Reporting Standards (IFRS) - Part 1

Practical Impact of New Accounting Rules - International Financial Reporting Standards (IFRS) - Part 2

11/08/2004 Joint ISDA Committee Meeting held on 8th November, 2004 (LONDON) Practical Impact of New Accounting Rules - International Financial Reporting Standards (IFRS)
10/22/2004 Andrea Pryde, IASB ISDA comment letter to IASB on ED-7 Disclosures for Financial Instruments
10/08/2004 Sandra Thompson, IASB ISDA comment letter to IASB on Amendments to IAS 39: Cash Flow Hedge Accounting of Forecast Intragroup Transactions
10/08/2004 Sandra Thompson, IASB ISDA comment letter to IASB on Amendments to IAS 39: Transition and Initial Recognition of Financial Assets and Financial Liabilities
10/08/2004 Andrea Pryde, IASB ISDA comment letter to IASB on Amendments to IAS 39 & IFRS 4: Financial Guarantee Contracts and Credit Insurance
09/2/2004 Suzanne Q. Bielstein
Financial Accounting Standards Board
Joint Working Group of ISDA, TBMA & SIA comments on Financial Accounting Standards Board's ("FASB") Exposure Draft (the "Exposure Draft"), Fair Value Measurements
07/21/2004 Sandra Thompson, IASB ISDA Comment letter on the IASB's ED on IAS 39 and the Fair Value Option
07/02/2004 Patrick Mommens, EFRAG Secretary General ISDA letter to EFRAG on their preliminary view's on the IASB's fair value option exposure draft
06/28/2004 Wayne Upton, Director of Research, IASB ISDA nominations to the IASB Financial Instruments Working Group
06/25/2004 Mr. Lawrence W. Smith, Financial Accounting Standards Board ISDA Comments on EITF Issue No. 04-7, "Determining Whether an Interest is a Variable Interest in a Variable Interest Entity"
06/25/2004 Ms Andrea Pryde, IASB ISDA Letter to IASB regarding Strengthening the IASB's Deliberative Procedures
05/18/2004 Mr Robert H. Hertz, Chairman, Financial Accounting Standards Board
ISDA Comments on FASB Statement 133 Implementation Issue No. D1, Application of Statement 133 to Beneficial Interests in Securitized Financial Assets
03/31/2004 Mr Robert H. Hertz, Chairman, Financial Accounting Standards Board ISDA Comments on the Revision to FASB Interpretation No. 46, Consolidation of Variable Interest Entities, ("FIN 46R")
1. ISDA Paper - Analyzing Derivatives Instruments under FIN 46R
2. Appendix A
03/12/2004 Mr Robert H. Hertz, Chairman, Financial Accounting Standards Board ISDA Comments on FASB Statement 133 Implementation Issue No. D1 and the finalization of IASB Statement No. 39
02/11/2004 Mr Tom Seidenstein, Director of Operations and Secretary, IASC Foundation ISDA representation on Identifying Issues for the IASC Foundation Constitution Review
01/12/2004 Mr Fabrice Demarigny, Secretary General, CESR ISDA's comments on the Draft No 2 On Financial Information Coordination of Enforcement Activities (Ref: CESR/ 03-317b)
01/12/2004 Paul Rutteman, EFRAG Secretary General ISDA's proposal for a Financial Instruments Sub-committee of EFRAG
11/20/2003 Sir David Tweedie, IASB ISDA comments and recommendations on proposed hedge accounting effectiveness testing under IAS 39
11/20/2003 Mr Fabrice Demarigny, Secretary General, CESR ISDA letter on CESR's "Draft Recommendation for Additional Guidance Regarding the Transition to IFRS"
11/17/2003 Ms. Sandra Thompson, IASB ISDA letter on the IASB's "macro hedging" proposal
06/05/2003 Mr.. Larry Smith, Director of Technical Application & Implementation Activities, Financial Accounting Standards Board Comments on FAS 133 Issue A23 - Definition of a Derivative: Prepaid Interest Rate Swaps
05/28/2003 Ms Sandra Thompson
  • ISDA IASB Meeting May 28th, 2003
  • Proposed IAS 39 Changes (Marked version)
  • Proposed IAS 39 Changes (Clean version)
  • 04/28/2003 Ms. Sandra Thompson ISDA IASB Meeting April 8th, 2003
    12/31/2002 Mr. Lawrence W. Smith, Director - EITF Chair, Financial Accounting Standards Board EITF Issue No. 02-3, “Issues Involved in Accounting for Derivative Contracts Held for Trading Purposes and Contracts Involved in Energy Trading and Risk Management Activities.
    10/31/2002 IASB ED1 First Time Application of International Financial Reporting Standards
    10/14/2002 Sir David Tweedie, Chairman International Accounting Standards Board
    Proposed Amendments to IAS 32 and IAS 39 Financial Instruments
    10/14/2002 Paul Ebling Esq, Accounting Standards Board Financial Reporting Exposure Draft 30 - Financial Instruments: Disclosure and Presentation, Recognition and Measurement
    9/16/2002 Mary Keegan, Accounting Standards Board
    Implementation of International Financial Reporting Standards (IFRS) in the UK
    9/16/2002 Paul Ebling Esq, Accounting Standards Board ISDA's Comments of FRED 23
    9/16/2002 Sir David Tweedie, Chairman of the International Accounting Standards Board Improvements to International Accounting Standards
    7/17/2002 Ms. Suzanne Bielstein, Director of Major Projects and Technical Activities, Financial Accounting Standards Board FASB Proposed Statement of Financial Accounting Standards, Amendment of Statement 133 on Derivative Instruments and Hedging Activities (Financial Guarantee Definition)
    7/01/2002 Ms. Suzanne Bielstein, Director of Major Projects and Technical Activities, Financial Accounting Standards Board FASB's Proposed Statement of Financial Accounting Standards, Amendment of Statement 133 on Derivative Instruments and Hedging Activities (D2 Model - Beneficial Interests)
    5/29/2002 Mr. Edmund Jenkins Chairman Financial Accounting Standards Board Special-Purpose Entity (SPE) Consolidation Criteria
    4/12/2002 Mr. Edmund Jenkins Chairman Financial Accounting Standards Board Proposed Interpretation of FASB Statement No. 94, Consolidation of All Majority-Owned Subsidiaries, and Accounting Research Bulletin No. 51, Consolidated Financial Statements
    3/26/2002 Educational Paper Explanation and Benefits of Fair Value Accounting
    2/01/2002 Educational Paper Special Purpose Entities (SPE's) and the Securitization Markets
    11/16/2001 Timothy S. Lucas, Chairman, Derivatives Implementation Group, Financial Accounting Standards Board Comments on Derivatives Implementation Group (DIG) Guidance on the Application of Statement 133 to Beneficial Interests in Securitized Financial Assets
    10/31/2001 The Secretariat of the Basel Committee on Banking Supervision Bank for International Settlements Working Paper on Pillar 3 - Market Discipline


    PROJECTS

    SUBJECT STATUS - DESCRIPTION AVAILABLE DOCUMENTS
    FASB Standard "Accounting for Derivatives and Similar Financial Instruments and for Hedging Activities" FASB proposes delaying implementation of FAS 133 until 2001.

    ISDA comment letter June 18, 1999 urging adoption of proposed delay.

    ISDA writes letter before FASB Board meeting in May indicating implementation problems are posing great difficulties for affected firms.

    ISDA Board approves policy of rapprochement with FASB
    ISDA Comment Letter June 18, 1999

    Letter from Alan Greenspan to Arthur Levitt dated June 4, 1998.

    Statement by Sen. D'Amato & Statement by Sen. Shelby

    Draft legislation 5 February 1998

    Letter from Rep. Richard Baker to Chairman Jenkins, 16 December 1997

    Draft legislation 14 November 1997

    ISDA letter to the FASB -- October 10 1997

    Testimony from the House and Senate meetings

    FASB Statement No.133 can be obtained from the FASB by calling 800-748-0659. Copies are $11.50 each.
    IASC Derivatives Proposed Accounting Standard IASC adopted IAS 39, Financial Instruments: Recognition and Measurement.

    *IASC working out implementation guidance.

    IAS 39, Financial Instruments: Recognition and Measurement Comment Letter, October 14, 1998; IASC Exposure Draft 62
    IASC Discussion Paper "Shaping IASC for the Future" The IASC proposes establishing a permanent structure to support its work. The organization would include broader representation than just accounting professionals. ISDA Accounting Committee supports concept but wants to insure structure and process that includes industry.

    ISDA Comment letter June 17, 1999
    BIS/IOSCO Consultative Paper "Recommendations for Public Disclosure of Trading and Derivative Activities of Banks and Securities Firms.

    BIS/IOSCO proposed disclosure standards similar to SEC Market Risk Disclosure Rule. ISDA Accounting Committee supports proposal in June 17 Comment Letter. ISDA Comment letter June 17, 1999
      Last Updated: March 9, 2011