The IACPM submitted a comment letter to the Basel Committee in response to the Consultative Document “Guidance on accounting for expected credit losses” released February 2015, addressing the topics of Use of Forward-looking Information, Guidance for Credit Risk Management versus Accounting, 12-month Expected Credit Loss, Significant Increases in Credit Risk, Use of Practical Expedient/Proportionality Issue, the Interaction between new Provision Approaches and Capital Treatment, Disclosure, Definition of Default and US GAAP.
