The Clearing House Association submitted a comment letter to the FASB responding to the exposure draft on insurance contracts.  The letter urges that the scope of the proposal is overly broad, as it may extend to many contracts that are better accounted for under the FASB’s existing guidance for guarantees. These contracts either consist of financial contracts that do not meet the definition of insurance risk, such as financial guarantees, standby letters of credit, and liquidity facilities, or consist of indemnifications or guarantees that are incidental to a larger transaction and are intended merely to ensure that a seller satisfies its own performance obligation to a customer.