The Committee on Corporate Reporting ("CCR") of Financial Executives International ("FEI") wishes to share its views on the proposed Accounting Standards Update on Balance Sheet (Topic 210), Offsetting, (the "Proposed ASU") as issued by the Financial Accounting Standards Board ("FASB"), and the Exposure Draft ED/2011/11, Offsetting Financial Assets and Financial Liabilities, as issued by the International Accounting Standards Board ("IASB") (collectively, the "Exposure Drafts").