In our comments responding to the FASB’s proposed amendments to ASU 2024-03, we believe that the proposal eliminates any potential ambiguity about the initial effective date for entities that do not use an annual reporting period ending on December 31 (called “non-calendar year-end entities”). We believe that the proposal clarifies the guidance is effective for interim reporting periods within annual reporting periods beginning after December 15, 2027; without this clarification, a non-calendar year-end reporting entity could misconstrue that it is required to adopt the guidance in an interim reporting period.
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