M E M O R A N D U M

TO:	Rule-Comments
FROM:	Jenifer Minke-Girard
DATE:	November 5, 2002
RE:	Release Nos. 33-8098; 34-45907; International Series Release No. 1258 File No. S7-16-02

On November 5, 2002, Eric Schuppenhauer, Greg Faucette, and Jenifer Minke-Girard of the Office of the Chief Accountant met with representatives of the Accounting Committee of the American Bankers Association about, among other topics, the proposed disclosure in Management's Discussion and Analysis (MD&A) about companies' critical accounting estimates and the initial adoption of material accounting policies. During the meeting, ABA members expressed the following views:

• In preparing final rules, the staff and Commission should consider providing more specific guidance about the "range of reasonable possibilities" for a critical accounting estimate disclosed as part of the quantitative disclosures, if a company chooses that disclosure alternative. In particular, it would be helpful to understand whether the range should be estimated using information available as of a point in time (e.g., a period end) or should incorporate future expected changes in assumptions or variables used to determine the accounting estimate.

• In preparing final rules, the staff and Commission should consider an effective date that gives preparers adequate time to comply. In particular, if the final rules will be adopted close to the end of 2002, the ABA representatives requested that the effective date be something later than periods ended 12/31/2002.