Deloitte comment letter on Draft IFRS [X] 'Liabilities'
We disagree with the Board’s decision to limit re-exposure of the revised IAS 37 to the measurement proposals only, and not provide constituents with an opportunity to comment on the entire draft Standard. In so doing, we do not believe that the Board has adhered to the spirit of due process. The aspects of the proposals in the 2005 Exposure Draft to which we (and many other respondents) were strongly opposed were not limited to the measurement guidance. The Board made available a working draft of the Standard (the ‘Working Draft’) on 19 February 2010, although it is still incomplete and does not include a Basis for Conclusions or Illustrative Examples.
We urge the IASB to consider all unsolicited comments on the sections of the working draft other than the measurement proposals. We believe that the proposed change to the recognition criteria is so significant and so inextricably linked to the measurement guidance that it cannot be understood in isolation and without putting it within the context of the entire draft Standard.