ELFA FASB Exposure Draft comment letter v14 clean

December 13, 2010 Ms. Leslie Seidman Acting Chairman Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk, CT 06856-5116 Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Submitted via electronic mail to director@fasb.org Re: File Reference: No. 1850-100, Exposure Draft: Leases Dear Madam and Sir, The Equipment Leasing and Finance Association welcomes the opportunity to respond to the request for comments from the Financial Accounting Standards Board (FASB) and the International Accounting Standards Board (IASB) (collectively, the Boards) on the proposal contained in the FASB Exposure Draft, Proposed Accounting Standards Update: Leases Topic 840. The Equipment Leasing and Finance Association (ELFA) is the trade association representing over 600 financial services companies and manufacturers in the $521 billion U.S. equipment finance sector. ELFA members are the driving force behind the growth in the commercial equipment finance market and contribute to capital formation in the U.S. and abroad. Overall, business investment in equipment and software accounts for 8.0 percent of the GDP; the commercial equipment finance sector contributes about 4.5 percent to the GDP. For more information, please visit http://www.elfaonline.org. Equipment leases provide all types of equipment to all types companies but most importantly to ...