The Bank Policy Institute, on behalf of 50 of the largest banks operating in the US, has called on Treasury Secretary Mnuchin to work within the FSOC to delay implementation of the Current Expected Credit Loss accounting framework. CECL is a new credit loss accounting standard model issued by FASB in 2016, replacing the current Allowance for Loan and Lease Losses (ALLL) standard. The CECL standard focuses on estimation of expected losses over the life of the loans, while the current standard relies on incurred losses. In an October 17 letter, signed by BPI president and CEO Greg Baer and bearing the names of 50 of the largest and best known US-based banks and international firms with a significant US presence, BPI asks that FSOC "work to evaluate the systemic and economic risks posed by CECL and engage with [FASB] and regulatory agencies to seek a delay in CECL's implementation." Calling CECL "the most significant rewrite of US GAAP in the past 40 years," BPI warned that the proposal "could undermine financial stability in a future recession or financial crisis, as its requirements establish disincentives for banks to extend credit during stressed economic conditions." The letter argues that CECL would particularly impact banks subject to regulatory capital requirements, recently revised under the Basel III process, and that its impact could be even worse for bank's subject to Fed stress tests. Instead, BPI is seeking "changes to CECL to better reflect a financial institution's exposure to credit risk." As noted in a June 17, 2016, joint statement on the new accounting standard from the Fed, FDIC, NCUA and OCC, the effective dates for the new standard, which vary depending on the type of entity, don't kick in until December 2019 at the earliest – leaving "sufficient time to delay implementation to further study its shortcomings and mitigate its unintended consequences," the BPI letter states.