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ASA Supports Issuer Comment Letter on Treasury’s IRA Tax Credit Guidance



WASHINGTON, DC – The American Securities Association (ASA), along with several other trade associations, sent a letter to the U.S. Department of Treasury supporting a comment letter submitted by the Government Finance Officers Association (GFOA), the National Association of Counties (NACo), and the National League of Cities (NLC) regarding the proposed rules governing the Inflation Reduction Act’s (IRA) Tax Credit Elections for qualifying energy property projects.

“Our organizations represent finance professionals from banks, underwriting firms, and municipal advisory firms that assist state and local governments with bond transactions and other financings,” wrote the Associations.

“We strongly agree with the general theme of the GFOA et al letter…Without clarity and adjustments in the key areas discussed in this letter - pre-awarded project certification process; the program’s ongoing compliance and reporting requirements; and potential market and cost impacts from regulatory risks associated with the program - we too are concerned that the program will not be utilized in the public sector, as intended by Congress.”

In June 2023, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released guidance on key provisions in the Inflation Reduction Act to expand the reach of the clean energy tax credits. Current pre-filing requirements state taxpayers must maintain onerous mandatory information and registration filings.

In a letter to Treasury and the IRS, GFOA, NLC, and NACo state, “While we appreciate Treasury’s acknowledgement that renewable electric generating projects and the acquisition of electric vehicles (EVs) and EV charging infrastructure are complex in nature and also the inclusion of broader market participants as eligible “agencies or instrumentalities” in the proposed regulations, we remain concerned about the required complex pre-filing processes, the challenges that ongoing compliance and reporting will require, the overall cost of compliance, and the increased risks that collectively the rules currently present.”


The full comment letter can be found here.



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About the American Securities Association


American Securities Association, based in Washington, DC, represents the retail and institutional capital markets interests of regional financial services firms who provide Main Street businesses with access to capital and advise hardworking Americans how to create and preserve wealth. ASA’s mission is to promote trust and confidence among investors, facilitate capital formation, and support efficient and competitively balanced capital markets. This mission advances financial independence, stimulates job creation, and increases prosperity. The ASA has a geographically diverse membership of almost one hundred members that spans the Heartland, Southwest, Southeast, Atlantic, and Pacific Northwest regions of the United States.

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