MFA submitted a letter to the Financial Accounting Standards Board (FASB) in response to proposed updates to accounting standards framework. MFA supports the FASB continuing work to improve consistency and integrity in the fair value measurement framework and offers these comments in that constructive spirit.
MFA provides the following suggestions:
- Bifurcate the scope of the final standard.
- Confine the Proposed ASU “equity security” concept to Level 1 equities.
- Make the rule mandatory, not optional, for all registered funds.
- Do not extend the Proposed ASU to other asset classes.
- Disclosure. An additional justification for excluding private funds from the Proposed ASU is that they do not make position-by-position disclosures to investors.
- Transition and effective date.
