Notes from the Field – the 2025 AICPA & CIMA Conference on Banks & Savings Institutions and Conference on Credit Unions

By John Marsh October 31, 2025

The financial services industry continues to navigate a complex and evolving landscape shaped by regulatory changes, economic uncertainty, and technological disruption. I recently attended the 2025 AICPA & CIMA Conference on Banks & Savings Institutions and Conference on Credit Unions. Speakers at the conference, which took place September 15 – 17 in National Harbor, Maryland, covered a variety of topics affecting financial institutions as well as the accounting and auditing profession. The conference aimed to provide strategic insights and practical guidance to help financial institutions adapt, innovate, and thrive in a dynamic environment. The conference explored key trends, emerging risks, and opportunities that will define the path forward for banks, credit unions, and other financial entities.

Economy

At the recent AICPA & CIMA Conference, two prominent economists—Todd Buchholz and Dr. Douglas Duncan—delivered compelling presentations that explored the current state and future trajectory of the U.S. economy and housing market.

Todd Buchholz’s presentation, titled “Prosperity Ahead – or Not?”, painted a dynamic picture of the global economic landscape, emphasizing both the strengths and vulnerabilities of the U.S. economy. He highlighted America’s resilience, noting that despite global headwinds, the U.S. continues to outperform its peers in GDP growth, innovation, and venture capital investment. Buchholz described the U.S. as a “cowboy economy,” leading the world in pharmaceuticals, energy, cloud computing, and startup culture, with more unicorn companies than the entire European Union. He also pointed to significant productivity gains, evidenced by the dramatic reduction in labor hours required to purchase consumer goods since the 1960s.

However, Buchholz cautioned that several risks loom large. The U.S. debt-to-GDP ratio has now exceeded levels seen during World War II, and aging demographics are placing increasing pressure on social systems. Trade tensions, particularly tariffs and protectionist policies, threaten global cooperation and could stoke inflation. Rising inflation has already led to more frequent labor strikes and wage demands, while supply chain disruptions continue to affect key sectors such as housing, food, and consumer goods.

Cultural and behavioral shifts are also reshaping the economy. Consumption patterns are moving away from traditional goods like beer and cars, toward health, technology, and experiential spending. The rise of remote work has given birth to the “homebody economy,” influencing real estate, fitness, and travel industries. Despite these challenges, Buchholz expressed optimism about the future, citing transformative innovations in artificial intelligence, energy, and 3D printing. He also noted that global improvements in education, literacy, and poverty reduction offer hope for sustained progress.

Dr. Douglas Duncan followed with a presentation titled “How Long Can This Keep Goin’ On?”, offering a data-driven analysis of the U.S. housing market and broader economic indicators. He acknowledged that while economic growth remains strong, it is beginning to slow, and disposable income growth has softened. Unemployment remains low but is gradually rising, and core inflation continues to exceed the Federal Reserve’s target, complicating monetary policy decisions.

In the housing sector, affordability remains a major concern. Mortgage rates are above long-term averages, and elevated home prices are making it harder for many Americans to buy homes. Duncan noted significant regional divergence in home price trends, with some areas experiencing sharper increases than others. New home starts are slightly below average, and sales have plateaued. Meanwhile, the supply of new homes has reached its highest level since the Global Financial Crisis, and existing home inventory is growing due to slower sales.

Mortgage borrowing trends mirror the pace of home sales, with originations slowing. Although mortgage delinquencies remain low, they are expected to rise modestly. Mortgage debt has tripled since 2000, and the Federal Reserve continues to be the largest holder of residential mortgage securities.

Looking ahead, Duncan warned of potential risks including stagflation or recession if economic growth continues to slow while inflation remains elevated. A reversal in Fed policy could become necessary if inflation persists above target levels. He suggested that improvements in housing affordability may come more from price declines than income growth. Finally, demographic shifts—particularly an aging population and evolving immigration patterns—will play a critical role in shaping future housing demand.

Artificial Intelligence (AI)

Dr. Lamont Black’s presentation delivered a powerful message to financial institutions: artificial intelligence is no longer a futuristic concept—it is a strategic imperative. Since its inception in 1956, AI has evolved into a transformative force that now permeates both business operations and everyday life. Currently, over 80% of organizations are leveraging AI in at least one business function, signaling a rapid acceleration in adoption.

To navigate this new landscape, it’s essential to understand the different types of AI. Machine learning enables data-driven pattern recognition, while generative AI (GenAI) powers content creation across text, video, and code. Agentic AI takes things a step further, allowing for autonomous decision-making. Depending on the application, AI can augment, automate, or fully delegate tasks—making it a versatile tool for innovation and efficiency.

GenAI tools have become mainstream, with platforms like ChatGPT, Microsoft Copilot, Anthropic Claude, Meta LLaMA, and Google Gemini leading the charge. These technologies are revolutionizing how financial institutions create content, engage with customers, and make strategic decisions.

Within the credit union sector, AI adoption is still in its early to mid-stages. Only 9% of credit unions report full integration of AI, though larger institutions—those with over $1 billion in assets—are slightly ahead in implementation.

Internally, AI is transforming operations by enhancing lending decision models, enabling real-time fraud detection, and streamlining internal support through knowledge assistants.

Externally, AI is reshaping the customer experience. Chatbots now provide efficient self-service and support, while predictive analytics help institutions offer the “next best product” to customers. Personalization is also on the rise, allowing for tailored services and communications that better meet individual needs.

Dr. Black emphasized that AI is not merely an IT initiative—it represents a fundamental shift in organizational strategy. Every executive, from the CEO to the CFO, must define AI priorities that align with broader strategic goals. A clear and actionable AI roadmap is essential for guiding adoption and integration across departments.

Leadership and governance play a critical role in this transformation. Boards and executive teams must be actively involved in AI strategy discussions, ensuring that AI literacy and responsible governance are in place to support ethical and effective deployment.

Ultimately, Dr. Black concluded on an optimistic note: with thoughtful planning and cross-functional leadership, AI holds immense potential to drive efficiency, spark innovation, and deliver greater value to customers. Financial institutions that embrace this change will be well-positioned to thrive in the age of AI.

Federal Banking Regulators

Federal banking regulators shared their forward-looking strategies and proposed reforms aimed at modernizing oversight and encouraging innovation throughout the banking sector.

The Federal Reserve Board (FRB), represented by Chief Accountant Lara Lylozian, outlined four strategic pillars guiding its regulatory agenda. First, the FRB is enhancing its supervisory approach by focusing on material financial risks and ensuring timely mitigation. Second, it is pursuing capital framework reform, which includes implementing the Basel III endgame, refining stress testing methodologies, and adjusting leverage requirements. Third, the FRB is reviewing its regulatory and information collection practices to ensure they remain relevant and aligned across agencies. Lastly, it is working to make the bank application process more transparent, predictable, and fair.

The Federal Deposit Insurance Corporation (FDIC), represented by Acting Chief Accountant Bryan Jonasson, proposed updates to Part 363.3 regulations to ease compliance burdens on smaller institutions. Key changes include raising the asset threshold for audit requirements from $500 million to $1 billion and increasing the internal control over financial reporting (ICFR) threshold from $1 billion to $5 billion. The FDIC also suggested revising audit committee requirements and introducing inflation-based indexing for biennial updates, which would help maintain regulatory relevance over time.

The Office of the Comptroller of the Currency (OCC), represented by Chief Accountant Amanda Freedle, emphasized a shift toward tailored supervision and regulatory innovation.  In the realm of digital finance, the OCC is actively licensing digital asset activities and collaborating with other agencies, especially considering the GENIUS Act, which supports stablecoin regulation.

From an accounting perspective, the federal regulatory panel highlighted several focus areas. It encouraged early involvement of accountants in mergers and acquisitions, particularly regarding pushdown accounting. It also stressed the importance of transparency and documentation in valuing mortgage servicing rights. Clarifications were provided around nonaccrual status rules, with a recommendation to utilize the OCC’s Bank Accounting Advisory Series. Additionally, the Current Expected Credit Losses (CECL) model is now well-integrated into practice, though thorough documentation remains essential.

Looking ahead, regulators are committed to engaging with industry stakeholders through structured reviews and surveys. These include quinquennial Call Report data reviews and decennial EGRPRA (Economic Growth and Regulatory Paperwork Reduction Act) reviews, both aimed at identifying and eliminating outdated or unnecessarily burdensome regulations.

Jonathan Gould – OCC

Comptroller Jonathan Gould of the OCC delivered a forward-looking regulatory update that emphasized the need for a more dynamic and resilient banking system. His remarks centered on recalibrating risk tolerance, modernizing supervisory frameworks, and embracing innovation to better position banks for the future.

Gould began by challenging the prevailing post-2008 regulatory mindset, arguing that risk tolerance has been set too low for too long. This overly cautious approach, he suggested, has constrained banks’ ability to serve as effective financial intermediaries. To address this, Gould advocated for greater flexibility for community banks, while maintaining rigorous oversight for systemically important institutions. His goal is to restore relevance to the banking sector by allowing institutions to take and manage risk in a more balanced and strategic manner.

In terms of regulatory and supervisory priorities, Gould called for a reassessment of capital and liquidity requirements, including Basel III standards and the Community Bank Leverage Ratio (CBLR). He proposed a holistic review of post-crisis regulations—such as recovery planning and heightened prudential standards—to ensure they support normal business operations rather than hinder them. Supervision, he emphasized, should be risk-based and tailored to the size and profile of each institution. For community banks, Gould suggested relief measures in areas like fair lending and Community Reinvestment Act (CRA) compliance.

Addressing the controversial issue of debanking, Gould expressed concern over the exclusion of legal businesses, including cryptocurrency firms, from banking services. He announced that the OCC is taking steps to prohibit the use of reputational risk as a factor in bank evaluations and is reforming Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance practices to ensure fair access across the financial system.

Innovation was another key theme of Gould’s presentation. He stressed the importance of regulatory optionality for banks exploring emerging technologies such as artificial intelligence, digital assets, and stablecoins. Rather than imposing rigid rules, the OCC aims to guide institutions in developing safe and sound innovation strategies that align with their business models and risk profiles.

Gould concluded by drawing a historical parallel between the OCC’s current role in overseeing stablecoin issuers and its original mission in the 1860s—ensuring currency stability. With new authority granted under the GENIUS Act, the OCC is “back in the currency game,” reaffirming its foundational role in maintaining trust and stability in the financial system.

Audit and Accounting Standards

The Auditing Standards Board (ASB) shared its strategic direction and upcoming initiatives aimed at strengthening audit quality and relevance in a rapidly evolving environment. The ASB reaffirmed its commitment to developing high-quality standards that serve the public interest, improving communication with stakeholders, and ensuring that standards remain applicable amid technological and regulatory shifts.

The speaker noted that the ASB’s 2025–2026 workplan includes several notable projects. A major focus is on fraud, with an exposure draft approved in May 2025 that seeks to clarify auditor responsibilities and reinforce professional skepticism. Another emerging area is ESG and sustainability attestation, where new standards and subject matter sections are in development, with an exposure draft vote anticipated in November 2025. Additionally, proposed updates to AU-C sections 330, 500, and 505 aim to align external confirmation procedures with PCAOB AS 2310. The ASB is also soliciting input for its 2026–2030 strategic plan to ensure its future initiatives reflect industry needs.

He noted that several standards are approaching their effective dates. SAS 146, which addresses quality management for engagements, becomes effective for periods beginning on or after December 15, 2025. SAS 149, focused on group audits, will apply to periods ending on or after December 15, 2026. Firm-level quality management standards—SQMS 1 and SQMS 2—along with SSAE 23, which amends attestation standards for quality management, are also set to take effect on December 15, 2025.

SAS 149 introduces a principles-based, risk-focused approach to group audits. It clarifies the roles and communication protocols between group and component auditors, emphasizing the importance of professional skepticism and access to relevant information. The new quality management standards (SQMSs) represent a shift toward a risk-based, scalable framework tailored to the unique circumstances of each firm. These standards also enhance governance, monitoring, and remediation processes, and introduce new requirements for networks and service providers.

The presenters from the Financial Accounting Standards Board (FASB) emphasized the FASB’s continuing refinement of its technical agenda to meet the evolving needs of financial reporting. The 2025 update reflects a strong emphasis on stakeholder engagement, priority projects, and future directions in standard setting, with a clear focus on transparency, relevance, and responsiveness to industry developments.

The panel noted that the FASB’s current technical agenda includes several high-impact projects. These range from improving accounting and disclosure for software costs to clarifying recognition and measurement in debt exchanges. The Board is also working on establishing standards for environmental credit programs and government grants, with the latter drawing on international guidance from IAS 20. Enhancements to Topic 326 are underway to better address purchased financial assets, particularly non-PCD loans. Additionally, refinements to derivatives and hedge accounting under Topic 815 are being considered, along with targeted improvements to the statement of cash flows for financial institutions. 

The speakers noted that during 2024–2025, the FASB conducted extensive outreach, engaging with over 200 stakeholders and receiving 129 formal responses to its Invitation to Comment (ITC). These respondents represented a broad spectrum of the financial ecosystem, including investors, preparers, practitioners, trade groups, and academics. Their feedback has helped shape FASB’s understanding of current challenges and priorities.

Stakeholder input revealed distinct areas of focus. Investors emphasized the need for enhanced disclosures, key performance indicators (KPIs), better reporting on asset retirement obligations, intangibles, and cash flows. Preparers highlighted concerns around principal versus agent considerations, alternative funding mechanisms, outdated disclosures, hedge accounting, and the equity method of accounting. Practitioners pointed to issues with liabilities versus equity classification, consolidation guidance, troubled debt restructurings, and transactions under common control.

The panel pointed out that FASB’s research agenda is equally forward-looking. It includes exploration into digital assets, with a focus on improving accounting and disclosure practices. The Board is also examining the treatment of intangibles, including internally developed intangibles and research and development. Other areas under review include commodities, financial KPIs, and the statement of cash flows. A unified consolidation model is also being considered to streamline current practices.

They further noted that the Emerging Issues Task Force (EITF) continues to address narrow-scope issues that can be resolved efficiently. Current topics include market-return cash balance plans and the recapture of mortgage servicing rights.

Looking ahead, FASB will analyze the feedback received through the ITC and adjust its technical and research agendas accordingly. A formal Agenda Consultation Report is scheduled for release in 2026, which will summarize stakeholder input and outline its influence on future standard-setting activities.

[Author’s note:  subsequent to the conference, ASU 2025-06, Intangibles—Goodwill and Other— Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software, and ASU 2025-07, Derivatives and Hedging (Topic 815) and Revenue from Contracts with Customers (Topic 606): Derivatives Scope Refinements and Scope Clarification for Share-Based Noncash Consideration from a Customer in a Revenue Contract, were issued as final updates by the FASB.]

Mergers & Acquisitions

There were two separate presentations related to mergers and acquisitions, one from a valuation and accounting perspective and one focusing on merger activity, metrics, challenges and key considerations.  The speakers noted that in 2025, the banking sector is experiencing a resurgence in merger and acquisition (M&A) activity, driven by strong earnings, strategic repositioning, and a more favorable regulatory environment. Deal volume and value have increased notably, with the first half of the year seeing a ~20% rise in deal value compared to the previous year. Larger transactions are returning to the market, and while 84% of deals announced early in the year were under $1 billion, regional consolidation is expected to accelerate.

Mid-sized and regional banks are actively pursuing M&A to expand both their physical and digital footprints. Profitability pressures are prompting institutions to seek cost efficiencies and diversify revenue streams. Competitive forces from FinTechs and non-bank lenders are also pushing traditional banks to innovate and adapt.

They noted that from an investment perspective, key financial metrics are guiding deal evaluations. Ideal transactions show earnings per share (EPS) accretion within the first two years and a tangible book value (TBV) earn back period of less than three years. Strategic deals typically fall within a price-to-TBV range of 130–170%, and post-deal returns on average tangible common equity (ROATCE) above 18–20% within two to three years signal strong value creation. Cost synergies (estimated cost savings as a % of target’s expense base) of 25–35% or more are considered solid for regional deals, and minimal impact on the CET1 capital ratio (less than 50 basis points) is preferred.

The speakers further noted that deal execution trends show shorter approval timelines, particularly for sub-$500 million transactions. Capital availability remains strong, with the top 20 banks holding approximately $253 billion in surplus capital, enabling strategic acquisitions and stock buybacks.

They pointed out that pre-announcement diligence is critical, encompassing financials, credit and capital structure, tax and operational exposure, human resources, and regulatory readiness. Institutions nearing $100 billion in assets must prepare for heightened supervisory expectations under the Large Financial Institution (LFI) framework. Basel III Endgame capital rules also require early modeling and integration into deal pricing. Harmonization of policies related to CRA, AML, BSA, and fair lending is essential for regulatory alignment and community engagement.

The presenters noted that from an accounting and valuation standpoint, ASC 805 governs business combinations, requiring fair value measurement of assets, liabilities, and noncontrolling interests. The acquisition method involves determining whether the transaction qualifies as a business combination, identifying the acquirer and acquisition date, and recognizing goodwill or bargain purchase gains. Fair value principles emphasize market participant assumptions and the “highest and best use” of nonfinancial assets.

Deposit valuation trends show that core deposit intangible (CDI) premiums tend to move in tandem with Fed Funds Rates, with forecasts ranging between 2.3% and 2.5% of core deposits. Liquidity cushions have finally rebuilt as loan-to-deposit ratios have declined from ~85% in 2019 to 74% in 2025.   Deposit composition is structurally more expensive as non-interest-bearing deposits now make up only 23% of total deposits, increasing funding costs.

Under CECL, purchased credit-deteriorated (PCD) assets are accounted for using a “gross-up” approach, where expected losses are added to the cost basis rather than expensed. Non-PCD assets, however, have credit losses recognized in net income at acquisition. A final Accounting Standards Update (ASU) expected in Q4 2025 will extend the gross-up approach to acquired financial assets in business combinations (subject to certain exceptions).  The scope of the final standard is expected to be narrower than initially proposed, focusing primarily on seasoned loan receivables, excluding credit card receivables. A loan is considered “seasoned” if acquired through a business combination or purchased more than 90 days post-origination without the acquirer’s involvement.  Held-to-maturity debt securities will not be in scope.

Valuation challenges persist, particularly in loan and CDI valuation. Combining CECL and market credit loss estimates is recommended, though discount rate estimation remains complex, especially for non-pass rated loans. CDI valuation requires careful estimation of customer attrition, restructuring costs, and deposit costs, using historical data, OCC benchmarks, and cost allocation models.

Derivatives

The speaker covered derivatives and hedging strategies and their practical implications and implementation approaches.  In an environment marked by margin compression and interest rate volatility, credit unions and community banks are increasingly turning to derivatives as strategic tools to manage risk and optimize funding costs. Institutions are leveraging instruments such as interest rate swaps, caps, floors, and collars to navigate the shifting rate landscape and protect their balance sheets.

The presenter noted that interest rate swaps remain a foundational hedging tool, allowing institutions to exchange fixed for floating payments—or vice versa—to manage rate exposure. Caps and floors function like insurance, offering protection against adverse rate movements in exchange for an upfront premium. Collars, which combine caps and floors, help institutions limit exposure within a defined interest rate range.

He further noted that strategically, many institutions are unwinding legacy pay-fixed swaps and replacing them with caps to better position themselves for potential rate declines. Forward-starting swaps are also gaining traction, enabling banks to lock in future funding costs and hedge repricing risk for upcoming maturities. Portfolio layer hedging is another innovative approach, allowing institutions to hedge closed portfolios—such as mortgage pools—using multiple swap layers with varying tenors.

The speaker pointed out that current market conditions present attractive opportunities. Implied volatility is at multi-year lows, making caps more affordable. Short-duration caps, particularly those with shorter maturities and strike rates between 3.5% and 4%, are especially appealing.

Finally, he noted that public institutions have been active in expanding their hedging programs.

Regulation Around Crypto

The speaker noted that the regulatory landscape for digital assets in the United States is undergoing rapid and significant transformation, shaped by executive actions, legislative developments, and evolving agency-level policies. Financial institutions are advised to closely monitor these changes to identify strategic opportunities and ensure compliance with emerging standards.

He pointed out that under the current administration led by President Trump, financial rulemaking has been centralized within the White House and the Office of Management and Budget (OMB), effectively limiting the ability of federal agencies to independently issue new regulations. Several executive orders from the previous administration, including those related to digital assets and central bank digital currencies (CBDCs), have been revoked. In their place, a new role—White House AI & Crypto Czar—has been established to coordinate federal policy on digital assets.

Among the most impactful executive actions is the creation of a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, signaling a national-level commitment to digital financial technologies. A separate executive order titled “Strengthening American Leadership in Digital Financial Technology” prohibits the development of a U.S. CBDC, promotes dollar-backed stablecoins, and directs federal agencies to identify and eliminate regulatory barriers to crypto innovation.

Legislatively, the GENIUS Act, passed in July 2025, marks a major milestone as the first comprehensive federal framework for stablecoins. It permits issuance by bank subsidiaries and OCC-regulated nonbanks, mandates 1:1 reserves in high-quality liquid assets, and requires disclosures and annual audits for large issuers. The act also imposes bank-like regulations and anti-money laundering (AML) compliance standards. Other legislative efforts include the CLARITY Act, which aims to divide digital asset oversight between the SEC and CFTC, and the Anti-CBDC Surveillance State Act, which prohibits the Federal Reserve from issuing a CBDC without congressional approval.

The speaker noted that federal agencies are also adjusting their stance. Banking regulators such as the OCC, FDIC, and Federal Reserve have rescinded prior guidance that required pre-approval for crypto-related activities. These agencies now reaffirm support for custody services, stablecoin issuance, and distributed ledger technology (DLT). The SEC has launched Project Crypto, positioning the U.S. as a global leader in digital asset regulation. This initiative includes FAQs and roundtables on decentralized finance (DeFi), custody, tokenization, and privacy, while explicitly excluding staking, meme coins, and mining from its jurisdiction. Meanwhile, the CFTC has initiated a Crypto Sprint to accelerate regulatory clarity.

He also pointed out that Congressional priorities continue to evolve. Market structure legislation is advancing, and concerns around de-banking—particularly the exclusion of crypto firms from traditional banking services—are under review. In a notable shift, Congress has overturned IRS rules that required DeFi platforms to report gross proceeds, signaling a more favorable tax policy environment for digital assets.

Finally, he noted that despite these developments, the U.S. regulatory system remains fragmented, with oversight shared among banking regulators (FRB, OCC, FDIC), market regulators (SEC, CFTC, FINRA, MSRB), and other authorities such as the CFPB, Treasury, and FSOC. For financial institutions, this evolving landscape presents both opportunities and challenges. Regulatory barriers to crypto engagement are being lifted, but institutions must prepare for increased scrutiny, enhanced reporting requirements, and strategic planning around digital asset offerings, custody solutions, and compliance frameworks.

Community Bank Financial Reporting Hot Topics

Community banks are navigating a complex financial reporting environment shaped by economic uncertainty, evolving accounting standards, and emerging business models.  The presenting panel members pointed out that loan demand is shifting, with term loan activity slowing due to interest rate volatility, while operating line usage may increase. These dynamics are influencing adjustments to the allowance for credit losses (ACL), requiring enhanced documentation, internal controls, and professional judgment.

As noted by the presenters, a major update from the Financial Accounting Standards Board (FASB) involves purchased financial assets (PFA). A final Accounting Standards Update (ASU) is expected by late 2025 to address the “double count” issue for non-purchased credit-deteriorated (non-PCD) assets. The new guidance will apply to loans and revolving credit arrangements, excluding credit cards and held-to-maturity securities. It introduces a gross-up measurement approach and permits pooling of originated and seasoned purchased loans. The effective date is set for fiscal years beginning after December 15, 2026, with early adoption allowed. Institutions acquiring banks in 2025 may elect to apply the new guidance retroactively to January 1, 2025.

Another change noted by the speakers is the replacement of troubled debt restructuring (TDR) guidance under ASU 2022-02. The focus now shifts to disclosing loan modifications for borrowers experiencing financial difficulty. They pointed out that this aligns with upcoming Call Report changes, effective December 2025, though agencies will not object to early adoption as of September 2025.

The panel also pointed out that the rise of Banking-as-a-Service (BaaS) and FinTech partnerships introduces new financial reporting challenges. Banks must evaluate credit enhancements to determine whether arrangements qualify as freestanding under ASC 326. Common pitfalls include unclear roles, regulatory ambiguity, execution speed, and misaligned risk frameworks.

They noted that in the area of Bank-Owned Life Insurance (BOLI) accounting, institutions are cautioned against recognizing gain contingencies prematurely. ASC 325 does not address gain contingencies, so ASC 450 guidance must be applied. Realizable amounts should reflect contractual limitations when determining value.

Further, they noted that sale-leaseback (SLB) transactions also require careful consideration. For sale accounting to be recognized, transactions must meet ASC 606 criteria. If a leaseback is classified as a finance lease or includes a repurchase option, sale recognition may be disqualified, impacting earnings and liquidity strategies.

Standard setters continue to advance key initiatives. The panel noted that the FASB has issued final ASUs on income tax disclosures (ASU 2023-09), disaggregation of income statement expenses (ASU 2024-03), as well as final ASUs related to segment reporting, crypto assets, and profits interest awards. Proposed updates include purchased financial assets, internal-use software costs, hedge accounting, environmental credit programs, and government grants. Meanwhile, the SEC pursuant to the Regulatory Flexibility Act is focusing on crypto integration, modernizing disclosures, and market innovation and efficiency.  [Refer to the author’s note earlier in this publication noting the final issuance of ASU 2025-06 and ASU 2025-07 by the FASB.]

Finally, they noted that the FDICIA proposed rule related to Part 363 includes new inflation-adjusted thresholds for audit committee and internal control over financial reporting (ICFR) requirements. The public comment period for these updates closed on September 26, 2025.

Get in Touch with the BNN team

Baker Newman Noyes is a leading regional accounting firm delivering assurance, tax, and advisory services to our clients. To discuss the topics above or any other banking topics, please contact Joseph Jalbert, our banking and financial services practice lead, or your BNN Advisor at 800.244.7444.