DHG’s Comment Letter Response to FASB’s Proposed Effective Date Deferrals for CECL, Derivatives and Hedging, Leases, and Long-Duration Contracts

Dixon Hughes Goodman LLP (DHG) has responded to the Financial Accounting Standards Board’s (FASB) invitation to comment on its Exposure Drafts, Financial Instruments—Credit Losses (Topic 326), Derivatives and Hedging (Topic 815), and Leases (Topic 842): Effective Dates and Financial Services—Insurance (Topic 944): Effective Date.

Overall, DHG is supportive of the FASB’s effort to provide additional time for certain companies to evaluate the impact and effectively implement the new current expected credit losses (CECL), leases, and hedging accounting standards. With the release of these multiple complex accounting standards with effective dates that are within relative proximity of each other, the FASB’s consideration to extend the effective dates will give affected entities needed additional time for adoption. We are similarly supportive of the FASB proposed deferral of the effective date for ASU 2018‐12, Financial Services—Insurance (Topic 944): Targeted Improvements to the Accounting for Long‐Duration Contracts (ASU 2018‐12) for all entities.

Despite the deferred effective dates, however, impacted companies should not slow down their implementation efforts and should utilize this additional time to enhance their efforts to implement robust approaches in adopting these accounting standards that meet all their compliance and system needs. Furthermore, we encourage the FASB to utilize the additional time to continue assessing the guidance needs of companies impacted by the Proposed ASUs, particularly smaller public companies, private companies, not‐for‐profit organizations, and employee benefit plans, and develop implementation tools and practice guidance, as needed, to enhance adoption efforts.

Our responses are framed by our experiences serving private companies, middle-market public issuers, and non‐issuer brokers and dealers.