M E M O R A N D U M

TO:	Rule-Comments
FROM:	Eric Schuppenhauer
DATE:	July 24, 2002
RE:	Release Nos. 33-8098; 34-45907; International Series Release No. 1258 File No. S7-16-02

On July 10, 2002, Chief Accountant Robert Herdman, Deputy Chief Accountant Jackson Day, Deputy Chief Accountant Craig Olinger (DCF) and Professional Accounting Fellow Eric Schuppenhauer met with representatives of the Accounting Committee of the American Bankers Association. Following are comments received from that group.

Critical Accounting Policies

• ABA is concerned about how to make the information required by the proposed disclosure requirements useful, particularly with respect to the allowance for loan losses.

• ABA is concerned that the information required by the proposed disclosure requirements will be redundant with other disclosures required by current (i.e., Industry Guide 3) and proposed SEC disclosure requirements (Supplementary Financial Data).