Proposed Accounting Standards Update: Financial Instruments – Credit Losses (Topic 326) Measurement of Credit Losses for Accounts Receivable and Contract Assets for Private Companies and Certain Not-for-Profit Entities (File Reference No. 2024-ED900)

Dear Mr. Jackson:

We appreciate the opportunity to comment on the proposed Accounting Standards Update ("Update") referenced above. Our comments will be in the form of responses to the specific questions included in the proposed Update.

Questions for respondents

Question 1: Should the amendments in this proposed Update be limited to private companies and not-for-profit entities, excluding not-for-profit entities that have issued, or are conduit bond obligors for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market? Should the proposed amendments be expanded to include public business entities, all not-for-profit entities, or other types of entities? Please explain your reasoning.

We believe that the amendments in the proposed Update should be limited to private companies and all not-for-profit entities as we believe the proposed amendments will reduce overall costs and complexity for these entities without reducing decision-useful information provided to their financial statement users. Specifically as it relates to not-for-profit entities, we believe that not-for-profit entities that have issued, or are conduit bond obligors for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market should be included in the scope of the proposed amendments as we believe that these entities are more similar to private companies than public business entities in terms of accounting and financial reporting resources and the fact that the proposed amendments typically would not have a material effect on their estimates of expected credit losses for current accounts receivables and current contract assets. Regarding public business entities, we do not believe that the amendments in the proposed Update should be expanded to public business entities as they generally have the resources necessary to address the complexities in the existing guidance and as noted in the Update's Background Information and Basis for Conclusions, public business entities have not expressed concerns about significant costs or complexity associated with estimating expected credit losses for current accounts receivable and current contract assets.

Question 2: Should the proposed amendments apply to current accounts receivable and current contract assets arising from transactions accounted for under Topic 606?

Yes, we believe that the proposed amendments should apply to current accounts receivable and current contract assets arising from transactions accounted for under Topic 606 as our experience has been that the proposed amendments would typically not have a material effect on the estimate of expected credit losses for current accounts receivables and current contract assets, and therefore, would not reduce decision-useful information provided to financial statement users.