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CECL Implementation Delayed for Qualifying Entities

By Juan M. Arciniegas, Thomas P. Desmond, James M. Kane, Jennifer Durham King, Daniel C. McKay, II, James W. Morrissey & Mark C. Svalina on October 18, 2019
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On October 16, 2019, the Financial Accounting Standards Board (“FASB”) extended the implementation deadline for the current expected credit loss standard (“CECL”) for qualifying entities.  The new implementation deadlines are as follows:

January 1, 2020: Publicly-traded entities that file reports with the Securities and Exchange Commission (“SEC”).

January 1, 2023: Publicly-traded entities that qualify as “smaller reporting companies” (as defined by the SEC), publicly-traded entities that do not file reports with the SEC, and all privately-held entities.

This official delay in the CECL implementation deadlines comes as the Senate Committee on Banking, Housing and Urban Affairs completes its review of Senate Bill 1564 (Continued Encouragement for Consumer Lending Act), which would require FASB to work with, among others, the SEC, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System and the Consumer Financial Protection Bureau (collectively, the “Federal Agencies”), to review CECL’s impact on the banking industry and consumers generally.  Upon completion of this study, the Federal Agencies would then be required to submit a report of their findings to Congress.  Entities would not be required to comply with CECL until one year after the report is submitted to Congress.

Photo of Juan M. Arciniegas Juan M. Arciniegas

Mr. Arciniegas works primarily as a derivatives lawyer and covers markets for over-the-counter (OTC) derivatives, structured finance products and listed futures. He advises on every stage throughout the life cycle of a derivatives transaction, providing assistance to a wide range of market participants…

Mr. Arciniegas works primarily as a derivatives lawyer and covers markets for over-the-counter (OTC) derivatives, structured finance products and listed futures. He advises on every stage throughout the life cycle of a derivatives transaction, providing assistance to a wide range of market participants engaged in the markets in various capacities. Regulatory matters range from assisting clients on financial reform legislation, registration and membership with the CFTC, NFA, and other financial market utilities, to providing guidance to commercial end-users and sell-side participants on exemptions, cross-border access issues, and matters involving the overlapping jurisdiction of securities and commodities regulation. Transactional matters include the negotiation and implementation of comprehensive documentation for agency-MBS, cleared and OTC derivatives, FX, futures, loan-level hedging arrangements, prime brokerage, repurchase transactions, securities lending, structured finance transactions, and related industry protocols implementing changes in those markets. Mr. Arciniegas has appeared before the CFTC, the Federal Reserve, the SEC, and is a frequent speaker and published author on futures and derivatives topics.

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Photo of Thomas P. Desmond Thomas P. Desmond

Thomas P. Desmond is Co-Chair of the Executive Compensation & Employee Benefits practice group, a member of the firm’s Board of Directors and Chair of the firm’s Compensation Committee.

Mr. Desmond’s practice includes advising corporations and financial institutions with respect to executive compensation…

Thomas P. Desmond is Co-Chair of the Executive Compensation & Employee Benefits practice group, a member of the firm’s Board of Directors and Chair of the firm’s Compensation Committee.

Mr. Desmond’s practice includes advising corporations and financial institutions with respect to executive compensation, mergers and acquisitions, corporate finance and governance matters. His corporate engagements have included acting as advisor to boards of directors and to compensation, audit, governance and other special committees of boards of directors of public and privately held corporations.

Mr. Desmond is known nationally for his representation of corporations, compensation committees and executives with respect to employment, retirement and separation arrangements affecting senior executives, incentive compensation programs and related regulatory and disclosure requirements. His assignments in this area have included employment arrangements, compensation plans, and regulatory and disclosure matters relating to numerous organizations, including Ace Hardware, Beam, Calamos Investments, ConAgra, Delphi, Dimensional Fund Advisors, DIRECTV, Fifth Third, First Midwest, Fiserv, Harris Associates, Hershey, Hyatt, ING, LPGA, MB Financial, PepsiCo, PGA Tour, Protective Life, Stancorp Financial, Swiss Re, Tellabs, Treehouse Foods, Visa, United Way and a number of private equity-sponsored entities.

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Photo of James M. Kane James M. Kane
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Photo of Jennifer Durham King Jennifer Durham King
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Photo of Daniel C. McKay, II Daniel C. McKay, II
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Photo of James W. Morrissey James W. Morrissey
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Photo of Mark C. Svalina Mark C. Svalina
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  • Posted in:
    Financial
  • Blog:
    The 21st Century Banker
  • Organization:
    Vedder Price PC
  • Article: View Original Source

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