Comment letter on DIG issue E23

ISDA International Swaps and Derivatives Association, Inc. 360 Madison Avenue, 16th Floor New York, NY 10017 United States of America Telephone: 1 (212) 901-6000 Facsimile: 1 (212) 901-6001 email: isda@isda.org website: www.isda.org September 21, 2007 Mr. Russell G. Golden Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 Re: File Reference: Proposed Issue E23 Dear Mr. Golden: The International Swaps and Derivatives Association (“ISDA”) is pleased to provide the following comments with respect to the Financial Accounting Standards Board’s (the “FASB”) proposed FASB Statement No. 133 Implementation Issue E23, “Issues Involving the Application of the Shortcut Method under Paragraph 68” (the “DIG Issue”). ISDA members represent leading participants in the privately negotiated derivatives industry and include most of the world’s major financial institutions, as well as many of the businesses, governmental entities and other end users that rely on over-the-counter derivatives to manage efficiently the financial market risks inherent in their core economic activities. Collectively, the membership of ISDA has substantial professional expertise and practical experience addressing accounting policy issues with respect to financial instruments and specifically derivative financial instruments. The provision of the proposed DIG Issue that prohibits an entity to apply the shortcut ...