Re: Comments on ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9
|
|
- Allison Taylor
- 6 years ago
- Views:
Transcription
1
2
3 China Accounting Standards Committee April 11, 2012 Mr. Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London, EC4M 6XH United Kingdom Dear Mr. Hans Hoogervorst, Re: Comments on ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9 Thank you very much for your care and kind support of the convergence between China Accounting Standards and International Financial Reporting Standards. We are pleased to have an opportunity to comment on the Exposure Draft ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9 ( the ED ) issued by the International Accounting Standards Board ( IASB or the Board ). Our main comments on the questions in the ED are summarized as follows: 1.We basically agree with the proposals in the ED regarding the classification of financial instruments. 2.We support the restrictions on early application proposed by the ED. 3.If the Board may consider postponing the effective date of IFRS 9 again, we would recommend that the standard on financial instruments shall have the same effective date as the standard on insurance. 4.We welcome the ED s proposal of adding more guidance on the classification of financial instruments. However, we are concerned that certain wordings in B of the ED might cause misinterpretation in China and hence recommend removing the example related to Instrument B in B so as to avoid any impact on the Tel: (86 10) Fax: (86 10)
4 continuous convergence between China Accounting Standards and International Financial Reporting Standards, reasons are as follows: Firstly, the interest rate is the price of capital, as the standards issued by the Board never require evaluating whether the pricing mechanism of resources in a specific market is fair or market based, neither should IFRS 9 require an evaluation of the interest rate formation mechanism in a specific country. Secondly, in China, all banks must abide by the rule that interest rates of loans from financial institutions shall be adjusted according to the central bank's benchmark interest rate. Consequently, there are no opportunities for arbitrage, because such interest rate only reflects the loan principal s time value of money and the consideration of credit risk in corresponding period, without taking into account the consideration of other factors, accordingly, there will be no interest rate mismatch. If you have any questions concerning our comments, please feel free to contact Mr. Leng Bing, Accounting Regulatory Department of the Ministry of Finance of China ( MOF ) ( , lengbing@mof.gov.cn). Yours sincerely, Yang Min [signed] Director General, Accounting Regulatory Department, MOF, China Secretary General, China Accounting Standards Committee Tel: (86 10) Fax: (86 10)
5 China Accounting Standards Committee of Ministry of Finance, China Comments on the IASB s Exposure Draft ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9 I. General Comments Our general comments and suggestions on the ED are as follows: 1. We support the IASB's proposal of adding a new category of debt instrument investments measured at fair value through other comprehensive income. However, we disagree with the guidance regarding the judgment of contractual cash flow characteristics. Please refer to our response to Question 2 for our detailed comments. 2. We suggest that the cost measurement exception under the existing International Accounting Standard 39 Financial Instruments: Recognition and Measurement (IAS 39) shall be retained. According to the existing IAS 39, if the fair value of equity instrument investments cannot be reliably measured, the equity instrument investments held shall be measured at cost. Since the IASB started its project of amending the standards on financial instruments in 2009, we have, in many occasions, urged the Board to retain this exception so as to enhance the applicability of International Financial Reporting Standards to emerging economies. In addition, we noted that the US Financial Accounting Standards Board (FASB) has also retained such exception in its Exposure Draft Financial Instruments Overall issued in February Therefore, we believe that the IASB should retain such exception for the purpose of increasing applicability as well as enhancing convergence. 3. We recommend that the reversal of the cumulative change in fair value of equity instrument investments measured at fair value through other comprehensive income shall be allowed. For equity instrument investments not held for trading, if they are elected to be measured at fair value through other comprehensive income on initial recognition, we recommend that, on derecognition, the Board shall allow the cumulative changes in fair value recognised in other comprehensive income to be released to profit or loss for the current period. This will be conducive to maintaining the inherent consistency of International Financial Reporting Standards. 4. We recommend that the same effective date shall be established for both the standards on financial instruments and the standard on insurance. If the Board considers further postponing the mandatory effective date of the standards on financial instruments which is currently scheduled on January 1, 2015, we recommend that the Board shall ensure that the standards on financial instruments and the standard on insurance shall have the same effective date. Tel: (86 10) Fax: (86 10)
6 II. Responses to the questions in the ED The following are our detailed comments on the questions in the ED. Question 1: Do you agree that a financial asset with a modified economic relationship between principal and consideration for the time value of money and the credit risk could be considered, for the purposes of IFRS 9, to contain cash flows that are solely payments of principal and interest? Do you agree that this should be the case if, and only if, the contractual cash flows could not be more than insignificantly different from the benchmark cash flows? If not, why and what would you propose instead? Response: We agree that a financial asset with a modified economic relationship between principal and consideration for the time value of money and the credit risk could still be considered to contain cash flows that are solely payments of principal and interest. We agree that differences between contractual cash flows and benchmark cash flows being "not more than insignificant" is a criterion in principle when determining whether a modified economic relationship fulfills the contractual cash flow characteristics. However, we strongly disagree with certain specific guidance. Please refer to our comments on Question 3. Question 2: Do you believe that this Exposure Draft proposes sufficient, operational application guidance on assessing a modified economic relationship? If not, why? What additional guidance would you propose and why? Response: We consider the guidance provided by the ED is not sufficient, and the meaning of "more than insignificant" is not clear enough. Consequently, it is difficult to consistently apply such guidance in practice. We recommend that the IASB shall provide more sufficient guidance on the interpretation of "more than insignificant" and the determination of benchmark instrument. Question 3: Do you believe that this proposed amendment to IFRS 9 will achieve the IASB s objective of clarifying the application of the contractual cash flow characteristics assessment to financial assets that contain interest rate mismatch features? Will it result in more appropriate identification of financial assets with contractual cash Tel: (86 10) Fax: (86 10)
7 flows that should be considered solely payments of principal and interest? If not, why and what would you propose instead? Response: Even though we believe that most of the guidance is conducive to IASB in achieving its objective, we strongly oppose to the examples included in some specific guidance. We conclude that related examples in the application guidance might be misleading in China and cannot be implemented. We noted that in the Agenda Paper 6B published by the IASB in October 2012, IASB staff conducted a more detailed discussion and reached a conclusion on how the above principle should be applied to "a country with interest rate regulation". In this context, one example in the application guidance B in the ED will be misleading. According to the example included in the Agenda Paper 6B, after a country s central bank announces a new loan interest rate, a 5 year loan that will be due in 1 year should bear the interest for the remaining 1 year using the interest rate applicable to a 5 year loan. Accordingly, the Agenda Paper 6B concluded that the related contractual terms would cause "the interest rate is reset, but the frequency of reset does not match the tenor of the interest rate", i.e., "interest rate mismatch". However, in China's situation, subject to the restraint of relevant laws and contractual terms, both banks and borrowers cannot choose any interest rate other than the benchmark interest rate announced by the central bank. Under such circumstances, interest rate still only reflects the principal s time value of money and the consideration for credit risk, without taking into account other factors. Accordingly, there are no opportunities for arbitrage. Therefore, we believe that in this case, the economic relationship between the interest rate and the time value of money and the credit risk has not been modified. Due to the above reasons, we suggest removing the 20 th row of the table on page 28 of the ED, i.e., the wording beginning from "Likewise, if " to the end of that example. From our point of view, such removal will not impair relevant guidance, but rather, it could avoid misleading users. Alternatively, in the sentence "Likewise, if " in the example of "instrument B", the Board could further clarify that if the borrower cannot choose other interest rate, the instrument would be qualified for the contractual cash flow characteristics for measurement at amortised cost. Similarly, we also suggest removing paragraph 44 of Basis for Conclusions of the Exposure Draft. Question 4: Do you agree that financial assets that are held within a business model in which assets are managed both in order to collect contractual cash flows and for sale should be required to be measured at fair value through OCI (subject to the Tel: (86 10) Fax: (86 10)
8 contractual cash flow characteristics assessment) such that: (a) interest revenue, credit impairment and any gain or loss on derecognition are recognised in profit or loss in the same manner as for financial assets measured at amortised cost; and (b) all other gains and losses are recognised in OCI? If not, why? What do you propose instead and why? Response: We agree with this proposal. Question 5: Do you believe that the Exposure Draft proposes sufficient, operational application guidance on how to distinguish between the three business models, including determining whether the business model is to manage assets both to collect contractual cash flows and to sell? Do you agree with the guidance provided to describe those business models? If not, why? What additional guidance would you propose and why? Response: We support the guidance provided by the ED, however, we are concerned that it is not sufficient enough. We suggest that more specific guidance or examples shall be provided for the following: (1) the frequency, timing and volume of sales; (2) the specific methods of judging whether the effect of changes in investment policy would result in the change of business model; (3) the specific approaches to determine the extent of disaggregation of investment portfolio that has components with the objective of selling and those with the objective of holding. In addition, we noted that the framework for distinguishing the three business models is, in effect, transferring the complexity of measurements in the existing standards on financial instruments (especially the complexity of impairment) to the complexity of classification. We are concerned that as impairment may be more "auditable" than classification, this might put auditors into an unfavorable position in relevant disputes with audit clients. Therefore, we encourage the Board to provide more sufficient and specific guidance on distinguishing the three business models in order to enhance the auditability of the new standard. Question 6: Do you agree that the existing fair value option in IFRS 9 should be extended to financial assets that would otherwise be mandatorily measured at fair value through OCI? If not, why and what would you propose instead? Tel: (86 10) Fax: (86 10)
9 Response: We agree with this proposal. Question 7: Do you agree that an entity that chooses to early apply IFRS 9 after the completed version of IFRS 9 is issued should be required to apply the completed version of IFRS 9 (ie including all chapters)? If not, why? Do you believe that the proposed six month period between the issuance of the completed version of IFRS 9 and when the prohibition on newly applying previous versions of IFRS 9 becomes effective is sufficient? If not, what would be an appropriate period and why? Response: We are basically supportive of this proposal. However, we d like to bring the IASB to the attention that the time lag between the early adoption of the new standard on financial instruments and the mandatory adoption of the new standard on insurance might cause potential "mismatch" for insurance companies. Question 8: Do you agree that entities should be permitted to choose to early apply only the own credit provisions in IFRS 9 once the completed version of IFRS 9 is issued? If not, why and what do you propose instead? Response: We support this proposal. We agree that the application of other versions of IFRS 9 shall not be allowed until the completed version of IFRS 9 is issued and becomes effective so as to avoid any confusion caused by multiple versions. However, for the changes in the fair value of financial liabilities designated as at fair value through profit and loss due to changes in own credit, the effect attributable to changes in own credit shall be recognised in other comprehensive income, early application shall be permitted separately from the completed version of IFRS 9. As the relevant requirements under the current IAS 39 indeed might cause outcome contradictory to the general principles, permitting separate early application of the above provision will be conducive to rectifying such error. Question 9: Do you believe there are considerations unique to first time adopters that the IASB should consider for the transition to IFRS 9? If so, what are those considerations? Response: We have not yet encountered any such issues. Tel: (86 10) Fax: (86 10)
ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9
Tony Burke Director, Industry Policy & Strategy AUSTRALIAN BANKERS ASSOCIATION INC. Level 3, 56 Pitt Street, Sydney NSW 2000 p. +61 (0)2 8298 0409 f. +61 (0)2 8298 0402 www.bankers.asn.au 19 March 2013
More informationExposure Draft (ED/2012/4), Classification and Measurement - Limited Amendments to IFRS 9
27 March 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Re: Exposure Draft (ED/2012/4), Classification and Measurement - Limited Amendments to IFRS 9 Ladies
More informationClassification and Measurement: Limited Amendments to IFRS 9
Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9 Proposed amendments to IFRS 9 (2010) Comments to be received by 28 March 2013 Securities and Exchange Board of India (SEBI) welcomes
More informationIASB Exposure Draft on Classification and Measurement: Limited Amendments to IFRS 9
28 March 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir/Madam, IASB Exposure Draft on Classification and Measurement: Limited Amendments to IFRS
More informationThe LIAJ s Comments on the ED. Classification and Measurement: Limited Amendments to IFRS 9
The LIAJ s Comments on the ED Classification and Measurement: Limited Amendments to IFRS 9 Proposed amendments to IFRS 9 (2010) 28 March 2013 The Life Insurance Association of Japan (LIAJ) The Life Insurance
More informationOur Ref.: C/FRSC. Sent electronically through the IASB website ( 19 April 2013
Our Ref.: C/FRSC Sent electronically through the IASB website (www.ifrs.org) 19 April 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sirs, IASB Exposure
More informationFEDERATION BANCAIRE FRANCAISE
FEDERATION BANCAIRE FRANCAISE Banking supervision And Accounting issues Unit The Director Paris, March 281h 2013 Exposure Draft ED/2012/4 Classification and measurement: limited amendments to IFRS 9 Dear
More informationRe: Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9
16 April 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir/Madam, Re: Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9 On
More informationRe: Comments on IASB s Exposure Draft on Classification and Measurement: Limited Amendments to IFRS 9
March 27, 2013 Mr. Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Hans, Re: Comments on IASB s Exposure Draft on Classification
More informationComment Letter on Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9 (proposed amendments to IFRS 9 (2010))
Verband der Industrie- und Dienstleistungskonzerne in der Schweiz Fédération des groupes industriels et de services en Suisse Federation of Industrial and Service Groups in Switzerland 26 March 2013 International
More informationComment letter on ED/2017/3 Prepayment Features with Negative Compensation
Tel +44 (0) 20 7694 8871 15 Canada Square London E14 5GL United Kingdom mark.vaessen@kpmgifrg.com Mr Hans Hoogervorst International Accounting Standards Board 1 st Floor 30 Cannon Street London EC4M 6XH
More informationInternational Accounting Standards Board 30 Cannon Street London EC4M 6XH 28 th March 2013
International Accounting Standards Board 30 Cannon Street London EC4M 6XH 28 th March 2013 Ref.: Exposure Draft ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9, Proposed amendments
More informationI would appreciate your including our comments in your summary of analysis.
28 March 2013 International Accounting Standards Board 30 Cannon Street, London EC4M 6XH United Kingdom Dear Sir or Madam: The Korea Accounting Standards Board (KASB) has finalized its comments on Exposure
More informationRe: Invitation to comment Exposure Draft ED/2012/4 Classification and measurement: Limited amendments to IFRS 9 Proposed amendments to IFRS 9 (2010)
Ernst & Young Global Limited Becket House 1 Lambeth Palace Road London SE1 7EU Tel: +44 [0]20 7980 0000 Fax: +44 [0]20 7980 0275 www.ey.com International Accounting Standards Board 30 Cannon Street London
More informationInsurance Europe comments on the Exposure Draft: Conceptual Framework for Financial Reporting.
To: From: Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH Economics & Finance department Date: 18 November 2015 Reference: ECO-FRG-15-278 Subject:
More informationRe: Comments on the Exposure Draft Accounting Policy Changes (Proposed amendments to IAS 8)
27 July 2018 Mr. Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Re: Comments on the Exposure Draft Accounting Policy Changes (Proposed
More informationSubject: ED 2012/4 Classification and Measurement: Limited Amendments to IFRS 9
Mr. Hans Hoogervorst Chairman IASB 30 Cannon Street London EC4M 6XH United Kingdom Ref. G10507 FEB177093 Brussels, 27/03/2013 Subject: ED 2012/4 Classification and Measurement: Limited Amendments to IFRS
More informationComment Letter on Financial Instruments Exposure Draft
International Accounting Standards Board (IASB) First Floor 30 Cannon Street London, EC4M 6XH United Kingdom 15 September, 2009 Comment Letter on Financial Instruments Exposure Draft Dear Board Members,
More informationThe ANC welcomes the addition of a detailed illustrative example dealing with this issue.
AUTORITE DES NORMES COMPTABLES 5, PLACE DES VINS DE FRANCE 75573 PARIS CÉDEX 12 Phone 33 1 53 44 28 56 Internet http://www.anc.gouv.fr/ Paris, 5 th december 2014 N 40 M. Hans HOOGERVORST Chairman I.A.S.B.
More informationHans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH. To: Date: 14 January 2014
To: Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH Date: 14 January 2014 DP/2013/1: A Review of the Conceptual Framework for Financial Reporting Dear
More informationComments on the Exposure Draft Financial Instruments: Amortised Cost and Impairment
June 30, 2010 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir or Madame, Comments on the Exposure Draft Financial Instruments: Amortised Cost and Impairment
More informationThe IDW appreciates the opportunity to comment on the Exposure Draft Insurance
Mr Hans Hoogervorst Chairman of the International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom 23 October 2013 567/550 Dear Mr Hoogervorst Re.: IFRS Exposure Draft 2013/7
More informationC/O KAMMER DER WIRTSCHAFTSTREUHÄNDER
C/O KAMMER DER WIRTSCHAFTSTREUHÄNDER SCHOENBRUNNER STRASSE 222 228/1/6 A-1120 VIENNA AUSTRIA Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
More informationRe: Exposure Draft ED/2017/1 Annual Improvements to IFRS Standards Cycle
International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom 19 April 2017 Dear Mr Hoogervorst, Re: Exposure Draft ED/2017/1 Annual Improvements to IFRS Standards 2015-2017
More informationHans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH. 25 October Dear Mr Hoogervorst,
Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH 25 October 2013 Dear Mr Hoogervorst, Exposure Draft: Insurance Contracts We would like to thank the IASB
More informationBPCE s response to the Exposure Draft "Classification and Measurement Limited Amendments to IFRS 9"
International Accounting Standards Board Mr. Hans HOOGERVORST Chairman 0f the Board 30 Cannon Street London EC4M 6XH United Kingdom Transmitted by email to: commentletters@iasb.org Paris, 28 th March 2013
More informationExposure Draft ED 2013/10 Equity Method in Separate Financial Statements
Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ United Kingdom Tel:
More informationRe.: IASB Exposure Draft 2013/3 Financial Instruments: Expected Credit Losses
Mr Hans Hoogervorst Chairman of the International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom 19 June 2013 540 Dear Mr Hoogervorst Re.: IASB Exposure Draft 2013/3 Financial
More informationSubject: IBFed response to the IASB Exposure Draft Classification and Measurement: Limited Amendments to IFRS 9
Pinners Hall 105-108 Old Broad Street London EC2N 1EX tel: + 44 (0)20 7216 8947 fax: + 44 (2)20 7216 8928 web: www.ibfed.org Mr Hans HOOGERVORST Chairman International Accounting Standards Board 30 Cannon
More informationRe: Exposure Draft, Classification and Measurement: Limited Amendments to IFRS 9 IASB Reference ED 2012/4
277 Wellington Street West, Toronto, ON Canada M5V 3H2 Tel: (416) 977-3322 Fax: (416) 204-3412 www.frascanada.ca 277 rue Wellington Ouest, Toronto (ON) Canada M5V 3H2 Tél: (416) 977-3322 Téléc : (416)
More informationIFRS Project Insights Financial Instruments: Classification and Measurement
IFRS Project Insights Financial Instruments: Classification and Measurement 2 October 2012 The IASB s financial instrument project will replace IAS 39 Financial Instruments: Recognition and Measurement.
More informationDo you agree with the Board s proposal to amend the IFRS as described in the exposure draft? If not, why and what alternative do you propose?
Mr Hans Hoogervorst Chairman of the International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Düsseldorf, 31 August 2012 540/602 Dear Mr Hoogervorst Re.: IASB Exposure Draft
More informationRef: IASB s Exposure Draft Accounting Policy Changes Proposed amendments to IAS 8
ESMA Regular Use Date: 25 June 2018 ESMA32-61-271 Mr Hans Hoogervorst Chairman International Accounting Standards Board (IASB) 30 Cannon Street EC4M 6XH London United Kingdom Ref: IASB s Exposure Draft
More informationRESPONSE TO EXPOSURE DRAFT ON APPLYING IFRS 9 FINANCIAL INSTRUMENTS WITH IFRS 4 INSURANCE CONTRACTS (PROPOSED AMENDMENTS TO IFRS 4)
A S C ACCOUNTING STANDARDS COUNCIL SINGAPORE 5 February 2016 Mr Hans Hoogervorst Chairman International Accounting Standards Board 1 st Floor 30 Cannon Street London EC4M 6XH United Kingdom (By online
More informationRef: The IASB s Exposure Draft Clarifications to IFRS 15
The Chair 5 October 2015 ESMA/2015/1518 Ref: The IASB s Exposure Draft Clarifications to IFRS 15 Dear Mr Hoogervorst, Mr Hans Hoogervorst International Accounting Standards Board 30 Cannon Street London
More informationAccounting for Financial Instruments
International Financial Reporting Standards Accounting for Financial Instruments (IFRS 9) Executive IFRS workshop for Regulators Diplomatic Academy of Vienna Darrel Scott, IASB member The views expressed
More informationExposure Draft ED 2015/6 Clarifications to IFRS 15
Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ United Kingdom Tel:
More informationTurin, March 13, Mr. Hans Hoogervorst, Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
Turin, March 13, 2012 Ref.: Exposure Draft ED/2011/6 Revenue from Contracts with Customers Mr. Hans Hoogervorst, Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United
More informationExposure Draft Conceptual Framework for Financial Reporting
November 26 th, 2015 International Accounting Standards Board 30 Cannon Street, London EC4M 6XH United Kingdom Dear IASB members, Exposure Draft Conceptual Framework for Financial Reporting The Israel
More informationExposure draft zum RE-Exposure des IFRS 9
IASB Division Bank and Insurance Austrian Federal Economic Chamber Wiedner Hauptstraße 63 P.O. Box 320 1045 Vienna T +43 (0)5 90 900-DW F +43 (0)5 90 900-272 E Mail: bsbv@wko.at http://wko.at/bsbv Your
More informationINSTITUTE OF PROFESSIONAL ACCOUNTANTS OF RUSSIA
INSTITUTE OF PROFESSIONAL ACCOUNTANTS OF RUSSIA Member of International Federation of Accountants NP «Institute of Professional Accountants of Russia» (IPAR) Tverskaya strt., 22 b, building 3, Moscow,
More informationRe: Exposure Draft ED/2010/5 Presentation of Items of Other Comprehensive Income
Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ United Kingdom Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Tel:
More informationComment letter on ED/2014/5 Classification and Measurement of Share-based Payment Transactions
Tel +44 (0)20 7694 8871 15 Canada Square mark.vaessen@kpmgifrg.com London E14 5GL United Kingdom Mr Hans Hoogervorst International Accounting Standards Board 1 st Floor 30 Cannon Street London EC4M 6XH
More informationHans Hoogervorst Chairman International Accounting Standard Board (IASB) 30 Cannon Street London, EC4M 6XH
THE CHAIRPERSON Hans Hoogervorst Chairman International Accounting Standard Board (IASB) 30 Cannon Street London, EC4M 6XH EBA/2015/D/376 25 November 2015 Exposure Draft: Conceptual Framework for Financial
More informationExposure Draft ED/2012/4 - Financial Instruments: Classification and Measurement (Limited Amendments to IFRS 9)
March 18 th, 2013 International Accounting Standards Board 30 Cannon Street, London EC4M 6XH United Kingdom Dear Madam/Sir, Exposure Draft ED/2012/4 - Financial Instruments: Classification and Measurement
More informationFebruary 8, Mr. Hans Hoogervorst, Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
February 8, 2016 Mr. Hans Hoogervorst, Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom The Canadian Institute of Actuaries (CIA) is the national voice
More informationComment letter on Exposure Draft ED/2013/3 Financial Instruments: Expected Credit Losses
Mr. Hans Hoogervorst Chairman International Accounting Standards Board (IASB) 30 Cannon Street London EC4M 6XH UK IBA/C&I/2013/7419 6 August 2013 Dear Sir, Comment letter on Exposure Draft ED/2013/3 Financial
More informationMr Hans Hoogervorst Chairman IFRS Foundation 30 Cannon Street London EC4M 6XH United Kingdom (By online submission)
A S C ACCOUNTING STANDARDS COUNCIL SINGAPORE 30 October 2015 Mr Hans Hoogervorst Chairman IFRS Foundation 30 Cannon Street London EC4M 6XH United Kingdom (By online submission) Dear Hans RESPONSE TO EXPOSURE
More informationSAICA SUBMISSION ON THE EXPOSURE DRAFT ON FINANCIAL INSTRUMENTS: EXPECTED CREDIT LOSSES
5 July 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Email: CommentLetters@ifrs.org Dear Sir/Madam SAICA SUBMISSION ON THE EXPOSURE DRAFT ON FINANCIAL In
More informationDraft Comment Letter
Draft Comment Letter Comments should be submitted by 28 November 2014 to commentletters@efrag.org 12 September 2014 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
More informationRef: The IASB s Exposure Draft Applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts
The Chair Date: 29 January 2016 ESMA/2016/172 Mr Hans Hoogervorst International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Ref: The IASB s Exposure Draft Applying IFRS 9
More informationPrepayment Features with Negative Compensation (Proposed amendments to IFRS 9) Draft Comment Letter
EFRAG TEG conference call 26 April 2017 Paper 01-02 EFRAG Secretariat: Didier Andries, Joachim Jacobs, Ioanna Chatzieffraimidou This paper has been prepared by the EFRAG Secretariat for discussion at a
More information28 July Re.: FEE Comments on IASB Discussion Paper Preliminary Views on Revenue Recognition in Contracts with Customers
28 July 2009 Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street GB - LONDON EC4M 6XH E-mail: commentletters@iasb.org Ref.: ACC/HvD/SS/LF/ID Dear Sir David, Re.: FEE Comments
More informationRe: Exposure Draft, Investments in Debt Instruments - proposed amendments to IFRS 7
Deloitte Touche Tohmatsu 2 New Street Square London EC4A 3BZ United Kingdom Tel: +44 20 7007 0907 Fax: +44 20 7007 0158 www.deloitte.com www.iasplus.com 15 January 2009 Sir David Tweedie, Chairman International
More informationEuropean Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken
European Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken International Accounting Standards Board Brussels, 28 March 2013
More informationIASB Exposure Draft ED/2015/8 IFRS Practice Statement: Application of Materiality to Financial Statements
Our Ref.: C/FRSC Sent electronically through the IASB Website (www.ifrs.org) 26 February 2016 Mr Hans Hoogervorst International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
More informationISRAEL SECURITIES AUTHORITY Corporate Finance Department 22 Kanfei Nesharim Street, Jerusalem Tel: Fax:
ISRAEL SECURITIES AUTHORITY Corporate Finance Department 22 Kanfei Nesharim Street, Jerusalem 46959 Tel: 02-6556444 Fax: 20-5613152 www.isa.gov.il International Accounting Standards Board 30 Cannon street
More informationMr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Sent by email: Commentletters@ifrs.org Brussels, 20 January 2016 Subject: FEE comments
More informationExposure Draft ED/2011/6 - Revenue from Contracts with Customers
March 13 th, 2012 International Accounting Standards Board 30 Cannon Street, London EC4M 6XH United Kingdom Dear Madam/Sir, Exposure Draft ED/2011/6 - Revenue from Contracts with Customers The Israel Accounting
More informationRef: ED/2013/3 Financial Instruments: Expected Credit Losses
The Chairman, The IASB, 30 Cannon Street, London EC4M 6XH Paris, 1 July 2013 Dear Mr. Hoogervorst, Ref: ED/2013/3 Financial Instruments: Expected Credit Losses We are pleased to respond to the Invitation
More informationComments on Discussion Paper Preliminary Views on Revenue Recognition in Contracts with Customers
19 June 2009 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir or Madame Comments on Discussion Paper Preliminary Views on Revenue Recognition in Contracts
More informationEBF Comment Letter on the IASB Exposure Draft - Financial Instruments: Expected Credit Losses
Chief Executive DM/MT Ref.:EBF_001692 Mr Hans HOOGERVORST Chairman International Accounting Standards Board 30 Cannon Street London, EC4M 6XH United Kingdom Email: hhoogervorst@ifrs.org Brussels, 5 July
More informationThe International Auditing and Assurance Standards Board (IAASB) is pleased to provide comments on the IASB s Exposure Draft (ED) Investment Entities.
January 5, 2012 Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Hans, Re: Comments on IASB s Exposure Draft on Investment Entities
More informationExposure Draft: Financial Instruments: Expected Credit Losses
International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Stockholm 5 July 2013 Exposure Draft: Financial Instruments: Expected Credit Losses FAR, the Institute for the Accountancy
More informationConstituents generally agreed that IFRS 3 is conceptually sound, but that it is often difficult to apply in practice, in New Zealand.
30 May 2014 Mr Hans Hoogervorst Chairman The International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Hans Post-implementation Review of IFRS 3 Business Combinations
More informationOur ref. Comment letter on Discussion Paper DP/2018/1 Financial Instruments with Characteristics of Equity
Tel +44 (0) 20 7694 8871 15 Canada Square Reinhard.Dotzlaw@kpmgifrg.com London E14 5GL United Kingdom Mr Hans Hoogervorst International Accounting Standards Board Columbus Building 7 Westferry Circus London
More informationRe: ED 4 Disposal of Non-current Assets and Presentation of Discontinued Operations
` October 27, 2003 Sir David Tweedie Chairman IASB 30 Cannon Street London EC4M 6XH UK Dear David, Re: ED 4 Disposal of Non-current Assets and Presentation of Discontinued Operations On behalf of the European
More informationWe appreciate the opportunity to comment on the exposure draft mentioned above and would like to submit our comments as follows:
Mr Hans Hoogervorst Chairman of the International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Düsseldorf, 2 March 2012 540 Dear Mr Hoogervorst Re.: IASB Exposure Draft 2011/6
More informationDiscussion Paper - Accounting for Dynamic Risk Management: a Portfolio Revaluation Approach to Macro Hedging
THE CHAIRPERSON Hans Hoogervorst Chairman International Accounting Standards Board (IASB) 30 Cannon Street London EC4M 6XH 16 October 2014 Discussion Paper - Accounting for Dynamic Risk Management: a Portfolio
More informationRe: OIC response to the IASB Exposure Draft Financial Instruments: Impairment
Organismo Italiano di Contabilità OIC (The Italian Standard Setter) Italy, 00187 Roma, Via Poli 29 Tel. 0039/06/6976681 fax 0039/06/69766830 e-mail: presidenza@fondazioneoic.it Mr Hans HOOGERVORST Chairman
More informationIntergovernmental Working Group of Experts on International Standards of Accounting and Reporting (ISAR)
Intergovernmental Working Group of Experts on International Standards of Accounting and Reporting (ISAR) 31st SESSION 15-17 October 2014 Room XVIII, Palais des Nations, Geneva Friday, 17 October 2014 Afternoon
More informationProposed Accounting Standards Update, Financial Instruments Credit Losses (Subtopic )
Tel +44 (0)20 7694 8871 8 Salisbury Square Fax +44 (0)20 7694 8429 London EC4Y 8BB mark.vaessen@kpmgifrg.com United Kingdom Mr Hans Hoogervorst International Accounting Standards Board 1 st Floor 30 Cannon
More informationRe.: IASB ED/2013/2 Novation of Derivatives and Continuation of Hedge Accounting Proposed amendments to IAS 39 and IFRS 9
Mr Hans Hoogervorst Chairman of the International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom 8 April 2013 598/540 Dear Mr Hoogervorst Re.: IASB ED/2013/2 Novation of Derivatives
More informationSeptember 14, File Reference: Exposure Draft Financial Instruments: Classification and Measurement. Dear Sir David Tweedie:
1120 Connecticut Avenue, NW Washington, DC 20036 1-800-BANKERS www.aba.com World-Class Solutions, Leadership & Advocacy Since 1875 Michael L. Gullette VP Accounting & Financial Management Phone: 202-663-4986
More informationComment Letter on Exposure Draft ED/2017/5 Accounting Policies and Accounting Estimates (Proposed amendments to IAS 8)
Tel +44 (0) 20 7694 8871 15 Canada Square reinhard.dotzlaw@kpmgifrg.com London E14 5GL United Kingdom Mr Hans Hoogervorst International Accounting Standards Board 1st Floor 30 Cannon Street London EC4M
More informationJanuary 13, The Honorable Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London, EC4M 6XH United Kingdom
The Honorable Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London, EC4M 6XH United Kingdom Re: IASB Discussion Paper: A Review of the Conceptual Framework for Financial
More informationComment letter on ED/2015/5 Remeasurement on a Plan Amendment, Curtailment or Settlement/Availability of a Refund from a Defined Benefit Plan
Tel +44 (0)20 7694 8871 15 Canada Square mark.vaessen@kpmgifrg.com London E14 5GL United Kingdom Mr Hans Hoogervorst International Accounting Standards Board 1 st Floor 30 Cannon Street London EC4M 6XH
More informationCL October International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
26 October 2015 CL 33 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Comment Letter on the Exposure Draft on Clarifications to IFRS 15 Dear Sir/Madam, SwissHoldings,
More informationEuropean Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken
Mr. Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Brussels, 25 th November 2015 VH/MM/B16 Email: hhoogervorst@ifrs.org IASB Exposure
More informationHowever, we are uncertain that some of the provisions of the 2011 ED will actually improve financial reporting, specifically with respect to:
March 13, 2012 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Board Members: Consejo Mexicano de Normas de Información Financiera (CINIF), the accounting
More informationThe IASB s Exposure Draft Hedge Accounting
Date: 11 March 2011 ESMA/2011/89 IASB Sir David Tweedie Cannon Street 30 London EC4M 6XH United Kingdom The IASB s Exposure Draft Hedge Accounting The European Securities and Markets Authority (ESMA) is
More informationClassification and measurement: limited amendments to IFRS9
Classification and measurement: limited amendments to IFRS9 A consultation issued by the International Accounting Standards Board Comments from ACCA to IASB March 2013 ACCA (the Association of Chartered
More informationComment letter on ED/2012/3 Equity Method: Share of Other Net Asset Changes
Tel +44 (0)20 7694 8589 8 Salisbury Square mark.vaessen@kpmg.co.uk London EC4Y 8BB United Kingdom Mr Hans Hoogervorst International Accounting Standards Board 1 st Floor 30 Cannon Street London EC4M 6XH
More informationThis response summarizes the perspectives shared by our country members, as per the following due process.
December 18 th, 2014 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom RE: Invitation to comment on the Recognition of Deferred Tax Assets for Unrealised Losses (Amendments
More informationRe: Exposure Draft ED/2011/6 Revenue from Contracts with Customers
Hans Hoogervorst, Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Email: commentletters@iasb.org 09 March 2012 Dear Sir, Re: Exposure Draft ED/2011/6 Revenue
More informationRe : Exposure-Draft of proposed Amendments to IAS 39 Financial Instruments : Recognition and Measurement The Fair Value Option
CONSEIL NATIONAL DE LA COMPTABILITE 3, BOULEVARD DIDEROT 75572 PARIS CEDEX 12 Phone 33 1 53 44 52 01 Fax 33 1 53 18 99 43/33 1 53 44 52 33 Internet E-mail CHAIRMAN AB/MPC/MA N 469 www.finances.gouv.fr/cncompta
More informationBusiness Combinations II
April 2006 IASB Update is published as a convenience to the Board's constituents. All conclusions reported are tentative and may be changed or modified at future Board meetings. Decisions become final
More informationAOSSG comments on IASB Exposure Draft ED/2014/3 Recognition of Deferred Tax Assets for Unrealised Losses
19 December 2014 Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH UNITED KINGDOM Dear Hans AOSSG comments on IASB Exposure Draft ED/2014/3 Recognition
More informationCOUNCIL OF AUDITORS GENERAL. IASB Discussion Paper DP/2013/1 - A Review of the Conceptual Framework for Financial Reporting
ACAG AUSTRALASIAN COUNCIL OF AUDITORS GENERAL 8 November 2013 Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Mr Hoogervorst IASB
More informationProject Summary and Feedback Statement Financial Liabilities
October 2010 Project Summary and Feedback Statement Financial Liabilities Time line 2009 2010 2011 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Part 1: Classification and measurement IFRS 9 Finalisation of Financial Assets ED
More informationCommittee e.v. Accounting Standards
IFRS-Fachausschuss DRSC e. V. Zimmerstr. 30 10969 Berlin Hans Hoogervorst Chairman of the International Board 30 Cannon Street London EC4M 6XH Telefon +49 (0)30 206412-12 Telefax +49 (0)30 206412-15 E-Mail
More informationComment on the Exposure Draft ED/2010/6 Revenue from Contracts with Customers
22 October 2010 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir or Madame, Comment on the Exposure Draft ED/2010/6 Revenue from Contracts with Customers
More informationReference: IASB Exposure Draft Fair Value Option for Financial Liabilities
CEIOPS Westhafen Tower, 14 floor, Westhafenplatz 1 60327 Frankfurt Germany Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Contact: Carlos
More informationGrupo Latinoamericano de Emisores de Normas de Información Financiera
October 25, 2013 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Re: Exposure Draft (ED/2013/7) on Insurance Contracts Dear Board Members, The Group of Latin American
More information11 September Ref: 9/167. Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom
11 September 2009 Ref: 9/167 Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir David The International Association of Insurance
More informationRe.: IASB Exposure Draft 2014/1 Disclosure Initiative Proposed amendments
Mr Hans Hoogervorst Chairman of the International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom 21 July 2014 540/602 Dear Mr Hoogervorst Re.: IASB Exposure Draft 2014/1 Disclosure
More informationED/2013/7 Exposure Draft: Insurance Contracts
Ian Laughlin Deputy Chairman 31 October 2013 Mr. Hans Hoogervorst Chairman IFRS Foundation 30 Cannon Street London EC4M 6XH United Kingdom Dear Mr. Hoogervorst, ED/2013/7 Exposure Draft: Insurance Contracts
More informationFEE Comments on IASB Request for Information ( Expected Loss Model ) Impairment of Financial Assets: Expected Cash Flow Approach
11 September 2009 Sir David Tweedie Chairman International Accounting Standards Board Cannon Street GB LONDON EC4M 6XH S E-mail: commentletters@iasb.org Ref.: BAN/HvD/SS/LF/SR Dear Sir David, Re: FEE Comments
More informationFebruary 15, Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT
2011-200 Deloitte & Touche LLP 10 Westport Road P.O. Box 820 Wilton, CT 06897-0820 USA Tel: +1 203 761 3000 Fax: +1 203 834 2200 www.deloitte.com Ms. Susan M. Cosper Technical Director Financial Accounting
More informationDiscussion Paper DP 2014/1 Accounting for Dynamic Risk Management: a Portfolio Revaluation Approach to Macro Hedging
Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ United Kingdom Tel:
More information