The Clearing House Association submitted a letter to the FASB and IASB in response to the FASB’s and IASB’s proposal on impairment. TCH recommends that (i) the FASB and IASB develop a full-scope impairment model and expose it for comment, as it is difficult for our members to fully evaluate the proposal given its narrow scope and the insufficient time afforded to field test it; (ii) the definition of the bad book be based on the current U.S. GAAP definition of an impaired loan; (iii) the new approach be a conceptually sound model that also acknowledges the need for the application of significant judgment on the part of management; and (iv) the specific guidance for troubled debt restructurings be eliminated.