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Deloitte comment letter on the Conceptual Framework

Published on: Nov 25, 2015

Deloitte’s IFRS Global Office has responded to the IASB's exposure draft ED/2015/3, Conceptual Framework for Financial Reporting.

In its comment letter, Deloitte’s IFRS Global Office notes that it believes that further improvements are necessary before the revised Conceptual Framework is issued. Specifically, Deloitte’s IFRS Global Office thinks that:

  • The proposed material on the primary financial statements, and in particular the performance statement(s), suffers from a lack of a conceptual basis.
  • It is inappropriate to build rebuttable presumptions into the Framework.
  • The Framework would be enhanced by adding a statement that the Framework has been developed on the assumption that arm’s-length transactions between entities are fair exchanges — and then address those situations when that assumption might not hold, such as nonreciprocal transfers, at a standards level.
  • The proposed section on derecognition seems to have been written with collateralized borrowings (i.e., repo-type transactions) in mind, rather than addressing more general derecognition principles.
  • The exposure draft proposal will not provide guidance, criteria, or indicators that would help the Board decide between a current value and a cost-based amount.

Download the full comment letter below.

Download

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