The Bond Market Association and the International Swaps and Derivatives Association highlighted the importance of issuing standards that improve the usefulness of financial reports based on the needs of the report users and the need to balance costs and benefits of new standards in a comment letter filed with the Government Accounting Standards Board. The letter lays out the BMA's view that, when accounting for derivatives, a disclosure model is a more appropriate model given the unique aspect of government entities. It also provides comments from both associations about implementing fair value reporting of derivatives, including measure of hedge effectiveness, termination and change of intent, accounting for hybrid instruments, written opinions in a synthetic refunding, and transition requirements.

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