First, the EBF sees the changes to the treatment of hypothetical derivatives and the impact of paragraph B 6.5.5 on currency basis as being a change to current accepted practice (and US GAAP). The EBF thinks it inappropriate to use in IFRS the same wording as in US Guidance, but with a different meaning.
Furthermore, this issue has never been exposed, nor discussed during the elaboration of the standard. Given the implications of this paragraph, the EBF considers this first issue as being a fatal flaw.
The second issue relates to the treatment of open portfolios which, under a number of perspectives, lacks clarity. The EBF calls for the Board to amend the text in B 6.5.5 adequately and to allow institutions which macro hedge economically to continue to apply macro-hedge accounting until the open portfolio hedge accounting standard becomes available.
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