On July 2, ISDA submitted a letter to the Financial Accounting Standards Board (FASB) in response to its proposed Accounting Standards Update (ASU), Derivatives and Hedging (Topic 815) Fair Value Hedging – Portfolio Layer Method. ISDA supports the FASB’s efforts to clarify and improve US generally accepted accounting principles applicable to the hedging of a closed portfolio of prepayable financial assets. ISDA broadly believes the proposed guidance will reduce the complexity and clarify accounting and disclosures when hedging interest rate risk for portfolios of prepayable financial assets.