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Like EFRAG, FEE is supportive of the Board’s intention to defer the mandatory effective date of IFRS 9, and agrees that setting a fixed effective date in current circumstances – when completion of most of the financial instruments projects and possibly macro-hedging have been delayed to late 2011 or 2012 - should be reconsidered.
Also, as FEE stated in its letter to EFRAG on the 'IASB Exposure Draft Hedge Accounting' dated 28 February 2011, FEE believes that there is not only a need to consider all the interdependencies of all phases of the IFRS 9 project and other related IASB projects (e.g. insurance contracts), but also the outcome of the recent 'IASB’s Request for Views on the Effective Dates and Transition Methods'.
As noted in FEE´s comments on the IASB Exposure Draft 'Insurance Contracts' submitted to EFRAG on 29 November 2010, it would be ideal to bring in line the mandatory application of IFRS 9 and the final standard for insurance contracts. FEE agrees with the Board that this way, insurance undertaking would not have to face two rounds of changes in a short period.