On the recordMay 8, 2024
I include in the Record a letter dated April 6, 2023, sent by OCC Acting Comptroller Hsu to Chairman McHenry and Senator Lummis in response to their March 2, 2023, letter. Office of the Comptroller of the Currency, April 6, 2023. Hon. Cynthia Lummis, Committee on Banking, Housing, and Urban Affairs, U.S. Senate, Washington, DC. Hon. Patrick McHenry, Chairman, Committee on Financial Services, U.S. House of Representatives, Washington, DC. Dear Senator Lummis and Chairman McHenry: Thank you for your letter dated March 2, 2023, concerning the impact of the Securities and Exchange Commission (SEC) Staff Accounting Bulletin Number 121 (SAB 121) on institutions regulated by the Office of the Comptroller of the Currency (OCC). The OCC recognizes that the SEC plays an important role in developing financial reporting standards applicable to publicly listed companies in the United States. Federal law (12 U.S.C.1831n) requires all national banks and federal savings associations to follow reporting standards that are no less stringent than U.S. Generally Accepted Accounting Principles (GAAP), regardless of public listing status. We understand that these institutions, in consultation with their auditors, are analyzing the intersection of SAB 121 and GAAP. The OCC is monitoring these discussions. Please see responses below to your specific questions. (1) Was your agency contacted by the SEC prior to the issuance of SAB 121?…
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