June 27, 2022

VIA ELECTRONIC SUBMISSION

Paul Munter
Acting Chief Accountant
Office of the Chief Accountant
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: Update on Efforts to Implement Staff Accounting Bulletin No. 121 “Accounting for Obligations to Safeguard Crypto-Assets an Entity Holds for its Platform Users” (“SAB 121”)

Dear Mr. Munter:

The Securities Industry and Financial Markets Association (“SIFMA”)1 and the American Bankers Association (“ABA”)2 appreciated the opportunity to speak with the Securities and
Exchange Commission’s (“SEC”) Office of the Chief Accountant (“OCA”) and Division of Corporation Finance (collectively, the “Staff”) on June 3, 2022 regarding SAB 121 and our request to defer its effective date3. As discussed, our member firms are working diligently across various functions to bring to the Staff well-developed fact patterns for analysis – whether
individually, through the SIFMA and ABA Accounting Committees or through the Association of International Certified Professional Accountants Digital Asset Working Group (“DAWG”) – but this very time-consuming process is on-going.

1 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and
global capital markets. On behalf of our industry’s nearly one million employees, we advocate for legislation, regulation,
and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and
services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance,
and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.
With offices in New York and Washington, D.C., SIFMA is the U.S. regional member of the Global Financial Markets
Association (GFMA).

2 The American Bankers Association is the voice of the nation’s $24.0 trillion banking industry, which is composed of
small, regional, and large banks that together employ more than 2 million people, safeguard $19.9 trillion in deposits and
extend $11.4 trillion in loans.

3 Kevin Zambrowicz, SIFMA, and Michael Gullette, ABA, Letter to Paul Munter, Acting Chief Accountant, U.S. Securities
and Exchange Commission (May 27, 2022), available at https://www.sifma.org/wp-content/uploads/2022/05/SAB-121-
Deferral-Request-5.27.2022.pdf.