Deloitte comment letter on ED/2009/7 'Financial Instruments: Classification and Measurement'
We acknowledge the political and regulatory environment in which the IASB is operating. Requests for action by the G20 leaders on a replacement to IAS 39 that is available for use in 2009 have led to the acceleration of the classification and measurement aspects of this project. We commend the IASB for proposing an ED within such a short space of time with the aim of trying to fulfill this objective. Assessing the relative merits of the replacement to IAS 39 in parts clearly limits our ability to evaluate the proposals comprehensively as there are many areas that are yet to be finalised with which the classification and measurement proposals will interact. We therefore look forward to the issue of EDs on the other aspects of this project in order for us to understand and fully assess the replacement to IAS 39 in its entirety.
We note that the US FASB is currently deliberating its preferred model for financial instrument accounting. Tentative decisions to date indicate that the FASB are reaching different conclusions on some critical areas. We strongly encourage the IASB and FASB to work together over the coming months with the aim of ultimately agreeing to a single converged standard for financial instrument accounting. We appreciate that the IASB is managing multiple objectives such as revising financial instrument accounting within a short time frame and at the same time pursuing global convergence.
We support the IASB’s approach for a mixed measurement model for both financial assets and financial liabilities.