In the comment letter, we agree with the views in the exposure draft that for certain entities the measurement of investments in controlled subsidiaries at fair value provides the most relevant information, but we believe that criteria should be developed which better defines 'investment entities'. However, we disagree with the proposal that a non-investment entity parent of an investment entity should consolidate all entities it controls through its consolidated investment entity subsidiary. The following is an excerpt from the letter:
We believe that it is appropriate to establish a clear principle and criteria at the investment entity level that carries-over to the consolidated financial statements of a non-investment entity parent, rather than to prohibit the retention of investment entity accounting, or to impose barriers or restrictions that would result in differing accounting at the investment entity and consolidated levels.
Further, our comment letter expresses concern about the number of differences in the proposed accounting requirements between the IASB's exposure draft and the FASB's proposed guidance.
Click for our comment letter on Exposure Draft ED 2011/4 — Investment Entities.