Deloitte comment letter on Basel Committee's expect credit losses consultative document

Published on: 01 May, 2015

Deloitte Touche Tohmatsu Limited has responded to the Basel Committee on Banking Supervision’s consultative document, ‘Guidance on accounting for expected credit losses’.

In our comment letter, we support the Committee’s ini­tia­tive of introducing key supervisory principles for sound credit risk practices and for how these will interact with the accounting for expected credit losses for lending practices of banks. The comment letter focuses on three broad themes, which include:

  • Scope of the consultative document.
  • Consistency of the accounting technical requirements in the appendix of the consultative document.
  • Additional observation on the auditability of eleven credit risk principles.


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