We believe this equivalence project has made a valuable contribution to the shared understanding of both the common ground and the differences between the leading sets of GAAP and we are supportive of the concept of focusing on "real world outcomes of investor behavior" and efficient remedies that are targeted on what really matters to investors. However, we do have reservations about the role and capacity of the auditor in this regard, which we address in our detailed comments.

• Only two of the 12 investment banks have provided guidance for their analysts on how to integrate IFRSs into forecast models.
• Three-fourths of the investment banks offered their analysts no formal training at all on the adoption of IFRS.
• Half of the analysts surveyed have not made any changes to their forecast models for companies, while a further 23% have only made partial changes.
• Almost a third of the analysts have received no communication whatsoever from companies on the implications of IFRS. Less than 20% of analysts surveyed stated that companies had provided sufficient data.
• All agreed that the balance sheet and profit and loss account would be the financial statements most impacted by IFRS, thereby implying an increased focus on cash flows.
• Half stated that they would not be changing their valuation methods as a result of the adoption of IFRS, even though many responses highlighted potential impact on EV ratios, 'sum-of-the-parts' analysis, and dividend payments.

We believe the draft Interpretation is an appropriate and practical interpretation of IAS 39 Financial Instruments: Recognition and Measurement (IAS 39) and support its issuance. However, we do have two substantive comments. Firstly, we strongly encourage the IFRIC to clarify whether the assessment of hybrid instruments is required for an acquirer at the time of a business combination. Divergent views are already in existence on this issue, and D15 presents an opportunity to clarify this matter, similar to the issue set out in paragraph 3(b) of D15. Secondly, the IFRIC should clarify that the scope of D15 is limited solely to the 'closely related' decision, and not the other requirements in paragraph 11 of IAS 39.

We commend the Board in acting promptly to alleviate the concerns of constituents caused by the apparent inconsistency between the wording in IFRS 1 paragraph 36B and the discussion in the basis for conclusions on IFRS 6. We support the amendments as proposed in the exposure draft and encourage the Board to complete its redeliberations and issue the amendments in final form by 30 June 2005.