From FEE´s comments to the EFRAG’s draft endorsement advice on 22 June 20151, FEE reiterates its support for a swift endorsement of IFRS 9 in the EU. FEE also reiterates its support for solutions to address issues arising from the non-alignment of the effective date of IFRS 9 and the future standard on insurance contracts for those institutions with significant insurance activities.Preparers will need time to implement the requirements of the new standard but will be hesitant to begin this process until uncertainty surrounding the endorsement process is resolved.
FEE observes that the issue relating to the insurance industry continues to be of concern in Europe. FEE is also aware that similar concerns are expressed in other jurisdictions. Therefore, FEE reiterates its support for an international solution for this matter as a desirable outcome.
FEE acknowledges that, due to the complexity of the issue to be solved and as any solution will be of temporary nature, it cannot be expected to be perfect. FEE recognises that decisions will need to be made for the trade-off between different objectives. Overall, FEE considers important that any solution needs to ensure, to the extent possible, implementation at reasonable cost. It is equally important that the degree of complexity of any solution does not become a limiting factor for its implementation, audit, and understanding by the users of financial statements.
In that respect, FEE shares on a preliminary basis EFRAG’s view that a deferral solution would be preferable. FEE supports investigating further the scope of application of the deferral approach as it currently seems somewhat restrictive in practice for European companies.
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