On October 16, 2019, the Financial Accounting Standards Board (“FASB”) extended the implementation deadline for the current expected credit loss standard (“CECL”) for qualifying entities. The new implementation deadlines are as follows:

January 1, 2020: Publicly-traded entities that file reports with the Securities and Exchange Commission (“SEC”).

January 1, 2023: Publicly-traded entities that qualify as “smaller reporting companies” (as defined by the SEC), publicly-traded entities that do not file reports with the SEC, and all privately-held entities.

This official delay in the CECL implementation deadlines comes as the Senate Committee on Banking, Housing and Urban Affairs completes its review of Senate Bill 1564 (Continued Encouragement for Consumer Lending Act), which would require FASB to work with, among others, the SEC, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System and the Consumer Financial Protection Bureau (collectively, the “Federal Agencies”), to review CECL’s impact on the banking industry and consumers generally. Upon completion of this study, the Federal Agencies would then be required to submit a report of their findings to Congress. Entities would not be required to comply with CECL until one year after the report is submitted to Congress.