However, FEE feels that more could have been done in order to design a principle-based hedge accounting standard that would avoid undue complexity and many detailed rules. This is demonstrated by the rules for rebalancing of hedge relationships, complex treatment of the time value of options and missing solution for net positions and the sub-Libor issue in particular. As a further example of the detailed rules, FEE would like to raise the issue caused by text in B6.5.5, which prevents the use of the hypothetical derivative approach for cross currency interest rate swaps used as a combined hedge of long and short positions in different currencies, which is a common risk management market practise.
In addition to the above, FEE identified one critical issue in the review draft that needs in FEE's view immediate attention. In order to ensure that all hedge accounting for open portfolios that is currently enabled by IAS 39 Financial Instruments: Recognition and Measurement can be continued until the new macro hedging part of the financial instrument project is completed, attention needs to be paid particularly to the Implementation Examples F6.2 and F6.3 of IAS 39. It is vital that the wording and interpretation of the standard ensures that such eligible open portfolio hedges continue to be eligible until the final macro hedging approach is completed.
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