On October 21, ISDA submitted a response to the Financial Accounting Standards Board (FASB) on File Reference No. 2024-ED100, Derivatives Scope Refinements and Scope Clarification for a Share-based Payment from a Customer in a Revenue Contract. ISDA appreciates the FASB’s considerations on this topic and supports the reporting guidelines and clarifications to address questions raised by stakeholders. ISDA believes the FASB’s proposal will improve the application and relevance of the Derivatives and Hedging (Topic 815) and Revenue from Contracts with Customers (Topic 606) guidance and has provided potential refinements and improvements to the guidance in the letter.