Comment: ASC 848 proposals


In our comment letter in response to the FASB’s proposed ASU, Deferral of the Sunset Date of Topic 848 and Amendments to the Definition of the Secured Overnight Financing Rate (SOFR) Overnight Index Swap Rate, we agree with the Board’s proposal to

  1. Extend the sunset date of ASC 848, which provides relief for companies transitioning contracts that reference LIBOR to alternative reference rates, to December 31, 2024; and
  2. Broaden the definition of the SOFR Swap Rate to include term-based SOFR and other rates based on SOFR, in addition to the overnight rate.

To read our comments in full, including some clarifying remarks, download the comment letter here.



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