November 4, 2016 Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 By email:
[email protected] Re: File Reference Number 2016-310, Exposure Draft, Derivatives and Hedging (Topic 815) – Targeted Improvements to Accounting for Hedging Activities Dear Ms. Cosper, The International Swaps and Derivatives Association’s (ISDA)1 Accounting Policy Committee appreciates the opportunity to comment on the Financial Accounting Standards Board’s (“FASB”) Exposure Draft, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities (the “Exposure Draft”). Collectively, the Committee members have substantial professional expertise and practical experience addressing accounting policy issues related to financial instruments and specifically derivative financial instruments. This letter provides our organization’s overall views on the Exposure Draft and our responses to the questions for respondents included within the Exposure Draft. Overview ISDA supports the FASB’s efforts to simplify the accounting for hedging activities and address practice issues that have arisen under current generally accepted accounting principles (“GAAP”). We believe the Exposure Draft achieves the FASB’s objectives of improving the financial reporting of cash flow and fair value hedge relationships to better portray the economic results of an entity’s risk management activities in its financial statements and simplifying the application of hedge accounting guidance in current GAAP. 1 Since 1985, the International Swaps and Derivatives Association has worked to make the global derivatives markets safer and more efficient. ISDA’s pioneering work in developing the ISDA Master Agreement and a wide range of related documentation materials, and in ensuring the enforceability of their netting and collateral provisions, has helped to significantly reduce credit and legal risk.