For example, the Federal Reserve has required loan pools at one large bank to be re-consolidated into their financial statements when it was determined that risk and control were not removed from that organization through the creation of special purpose vehicles. In another example, the banking regulators have jointly issued for comment new guidance related to credit cards.
This guidance not only deals with unacceptable practices, but also clarifies that revenue recognition of fees billed to customers should reflect the expected ability to collect those fees. In addition to the recognition and measurement aspects of financial reporting, we need to continually evaluate the effectiveness of disclosures.