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Return to Comments
CECL Capital Proposed Rule
Type: Regulation
Federal Register Document Type: Proposed
Revise FCA’s Tier 1/ Tier 2 Regulatory Capital Framework (Capital Rule) to address changes to U.S. generally accepted accounting principles (U.S. GAAP) described in Accounting Standards Update No. 2016–13, Topic 326, Financial Instruments—Credit Losses (ASU 2016–13) and make conforming amendments to other regulations to accurately reference credit losses

Text of Comment Letter

Good Afternoon, 

Attached is Northwest Farm Credit Services’ comment letter on the Proposed Rule regarding Implementation of the Current Expected Credit Losses Methodology for Allowances, Related Adjustments to the Tier 1/Tier 2 Capital Rule, and Conforming Amendments – RIN 3052-AD36/ Federal Register 84, No. 184 (September 23, 2019). 

Please let me know if you have any questions. 

Thank you,


Colton Telford, CPA

2001 S Flint Rd,  Spokane, WA 99224

o 509.340.5349  │ m 509.590.3846

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