August 24, 2020

Hillary H. Salo
Technical Director
Financial Accounting Standards Board
401 Merritt 7, P.O. Box 5116
Norwalk, CT 06856-5116

Dear Ms. Salo:

PricewaterhouseCoopers LLP appreciates the opportunity to comment on the Proposed Accounting Standards Update, Financial Services-Insurance (Topic 944): Effective Date and Early Application.

We support the proposed one-year deferral of the effective date of ASU No. 2018-12, Financial Services - Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts (LDTI) for all entities and the transition relief provided if early application is elected. We commend the Board for taking expeditious steps in response to feedback from stakeholders.

The Appendix contains our detailed responses to the Questions for Respondents.

If you have any questions regarding our comments, please contact Mary Saslow at (860) 614-2102 or Jill Butler at (914) 806 3858.

Sincerely,

PricewaterhouseCoopers LLP

Yes, we support the deferral of the effective date by one year. We believe the deferral adequately addresses the industry’s concern that the overall effects of the pandemic have and will continue to impact implementation timelines in light of changed work environments and reprioritization of business initiatives. We believe the one year delay in the effective date for all entities will help ensure that entities are able to devote the necessary resources to implement the new guidance in a cost-effective high-quality manner.

Yes, we support the alignment of the early application transition date and the standard transition date proposed by the Board for early adopters for the reasons noted in the Proposed Accounting Standards Update Basis for Conclusions. While we believe that including three years of income statements on the same basis would provide better comparability, we agree that the expected benefit of presenting better information to users one year earlier than the proposed mandatory effective date justifies the reduced comparability.