The EBF does not consider that the consolidated cash flow statement of a bank provides useful information.
Credit institutions already publish information on liquidity and funding which users are likely to find more useful than the cash flow statement and a reconciliation of net debt. Therefore, the EBF suggests that it should be made clear that reconciliation of net debt is a disclosure, rather than a primary statement, and need not be provided in accordance with the concept of materiality being developed as part of the disclosure initiative.
The requirement to disclose restrictions on the ability to use cash and cash equivalent balances is similar to the existing requirement in IFRS 12 ‘Disclosure of Interests in Other Entities’ to disclose significant restrictions on the ability to access or use assets of the group (paragraph 13). Also the existing IAS 7 (paragraph 48) requires an entity to disclose restrictions on cash and cash equivalents.
In the interest of reducing duplicative disclosure requirements, it would be helpful to consider whether all these disclosures are necessary or at least to clarify how they are intended to provide different information.
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