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Financial Services Law Insights and Observations

OCC updates bank accounting guidance

Bank Regulatory Federal Issues Agency Rule-Making & Guidance OCC Supervision FASB Compliance

On August 15, the OCC released an annual update to its Bank Accounting Advisory Series (BAAS). (See also OCC Bulletin 2022-20.) Intended to address a variety of accounting topics relevant to national banks and federal savings associations and to promote consistent application of accounting standards and regulatory reporting among OCC-supervised banks, the BAAS reflects updates that clarify accounting standards issued by the Financial Accounting Standards Board related to, among other things, (i) “the amortization of premiums on debt securities with a call option over a preset period”; and (ii) “lessors’ classification of certain leases with variable lease payments.” The 2022 edition also includes answers to frequently asked questions from industry and bank examiners. The OCC notes that the BAAS does not represent OCC rules or regulations but rather “represents the Office of the Chief Accountant’s interpretations of generally accepted accounting principles and regulatory guidance based on the facts and circumstances presented.”