TCH has filed a comment letter responding to the Basel Committee on Banking Supervision’s (BCBS) proposal on prudential treatment of problem assets – definitions of non-performing exposures and forbearance. TCH is concerned that the proposal will affect current accounting and financial statement disclosure requirements, even though that is not necessarily the intended result. Therefore, TCH argues that the proposed definitions should be revised to align more closely with credit risk management practices to avoid creating an entirely new framework that may impact U.S. GAAP and IFRS financial statements without a corresponding improvement in credit risk measurements.