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Deloitte comment letter on Supplement to ED/2009/12 'Amortised Cost and Impairment'

Published on: 31 Mar 2011

We appreciate the efforts both Boards have made in developing proposals for a more operational expected loss model. Clearly understood and operational amortised cost and impairment measurement requirements are critical to the success of a mixed-measurement model. The Boards are to be commended in trying to develop proposals that cater for complex open portfolios.

We are generally supportive of an approach that recognises lifetime expected credit losses for performing assets (‘the good book’) on a time proportional basis with a minimum floor and recognises immediately lifetime expected credit losses for assets that are identified as non-performing (‘the bad book’) in full.


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