ACORE FASB ASU Comments on Proportional Amortization

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

RE: File Reference Number: 2022-004: Proposed Accounting Standards Update, Investments – Equity Method and Joint Ventures (Topic 323): Accounting for Investments in Tax Credit Structures Using the Proportional Amortization Method

Dear Ms. Salo:

The American Council on Renewable Energy (“ACORE”) is a national nonprofit organization dedicated to advancing the renewable energy sector through market development, policy changes and financial innovation. ACORE’s membership includes renewable energy developers, institutional investors, corporate buyers, electric power generators, retail energy providers, and other stakeholders interested in accelerating renewable energy investment in support of our nation’s climate and economic goals. ACORE values the opportunity to comment on the Proposed Accounting Standards Update (“the proposed ASU”) to expand the proportional amortization method of accounting to renewable energy tax credit structures. We appreciate the FASB’s continued attention to this issue, and we offer overall support for the proposed ASU.