Regulatory Comment Letters 

 

11 Aug 2011

Central Clearing of OTC Derivatives in Australia

Reval stresses the importance of ensuring that corporate end-users of derivatives are not forced to clear any trades nor have margin imposed for un-cleared trades and hopes that the Council of Financial Regulators will closely mirror the end-user clearing exemption from mandatory clearing proposed in the U.S. and EU.

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09 Mar 2011

IASB Exposure Draft: Hedge Accounting

Reval commends and supports the Board’s desire to align hedge accounting with risk management and to address the issues of the current guidance under IAS 39. We feel this is a significant step forward in providing users with useful information on the risk management activities of the reporting entity. The questions we address in our response to the IASB are intended to seek clarifications where we feel there is confusion or the potential for inconsistent application of the principle provided.

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31 Aug 2010

FASB Exposure Draft: Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities

Most of the comment letters to this Exposure Draft focus primarily on the proposed changes to ASC 825, and rightfully so, as we believe the proposed changes to ASC 825 represent a significant departure from current GAAP requirements. Our response, however, focuses primarily on proposed changes to ASC 815, which also represents a significant departure from existing GAAP and does not necessarily meet the proposed objectives of the changes.

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16 Jul 2010

IASB Exposure Draft: Fair Value Option for Financial Liabilities

We commend and support the Board’s desire to improve and simplify the accounting for financial instruments. However, we feel the approach outlined in the Exposure Draft is not consistent with the Memorandum of Understanding (“MoU”) jointly issued by the IASB and FASB, revised in 2008.

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06 Jul 2010

European Commission: Public Consultation on Derivatives and Market Infrastructures June 14, 2010

I commend the European Commission’s consultative and open approach in trying to best regulate the OTC derivatives market and appreciate this opportunity to provide a written response to certain questions referenced in the June 14, 2010 Public Consultation on Derivatives and Market Infrastructures.

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15 Aug 2008

FASB Exposure Draft: Accounting for Hedging Activities, and amendment of FASB Statement No. l33

We generally agree with the intent of the ED; however, we believe the ED should reconsider the following issues to achieve the goals stated above.

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Blog: Hedge Accounting Matters 

Reval experts weigh in on the current issues facing the hedge accounting world covering topics such as hedging policy, risk management, hedging strategy and upcoming financial regulation.

Blog: Risky Business 

Jiro Okochi, CEO and co-founder of Reval, shares his insight into derivatives, hedge accounting and risk management. With 23 years of experience in finance and technology, Mr. Okochi continues to serve the industry as a thought leader and is dedicated to helping companies better manage their use of derivatives.