We agree with the Board's objective to address the issue of own credit risk in the measurement of financial liabilities and further agree with the Board's decision to retain the basic model contained in IAS 39 Financial Instruments: Recognition and Measurement for classifying and measuring financial liabilities. However, we disagree with the Board's conclusion that credit risk can be identified following the approach set out in IFRS 7 Financial Instruments: Disclosures. The Board needs to articulate clearly the principle that underlies the mechanics of identification of credit risk and we believe that it is only the changes in fair value due to changes in one's own credit risk that should be identified separately and reported in other comprehensive income (OCI). In our view, own credit risk represents the risk that a reporting entity will not perform its financial obligations under a contract.

We generally agree with the proposals. In particular, we agree with the proposed definition of a reporting entity and with the requirement that a parent should present consolidated financial statements when it controls another entity. However, we do not believe that it is appropriate to define the concept of control as part of this chapter of the Conceptual Framework.

We agree with the conclusion that parent-only financial statements may provide useful information. However, we do not believe that the Conceptual Framework should specify the timing and the manner in which parent-only financial statements should be presented in relation to consolidated financial statements.