The Clearing House Association submitted a comment letter to the FASB and the IASB (the “Boards”) recommending that all standards have the same effective date, but with the option to early adopt any or all standards. TCH also recommends that the Boards adopt a prospective transitional approach for new standards wherever possible; recommends that if a single date approach is adopted, the Boards provide for approximately a five-year transition period, with an additional year for each year that is required to be presented on a retrospective basis; and recommends that the Financial Statement Presentation project be deleted from the Boards’ agendas before any major new standards are required to be implemented.