In addition, capitalized expenditures include direct payroll costs and interest costs incurred during development. Institutions should also capitalize costs to develop or obtain software that allows access or conversion of old data by new systems. National banks should continue to expense all costs associated with the first and third stages of software development. However, another amortization basis may be available if it is more representative of the software's use. National banks should also recognize and measure possible impairment of the capitalized software asset.
Earlier application is encouraged.