National Unrecovered Financial Services Association submitted a follow-up comment letter to the FRB, responding to questions raised at our September 20 meeting with respect to deferred tax asset calculations for regulatory-capital purposes under Basel III. The letter provides additional information with respect to several issues, including (i) an annual MSR election with respect to netting of DTLs; (ii) examples of transition rules; (iii) examples of provisions in the Current Rules that supplement U.S. GAAP; (iv) a comparison treatment of leveraged leases under U.S. GAAP and IFRS; and (v) an example illustrating application of the 10% and 15% threshold calculations during the transition period as recommended by SDUUK and that could be included in instructions to Call Reports (or FAQs). SDUUK also requests that DTLs arising from equity investments in unconsolidated financial institutions be treated in the same manner as DTLs associated with MSRs.

Related Documents:
Appendix 1