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Deloitte letter to EFRAG re IAS 39 'carve out'

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21 Sep 2004

Deloitte has written to EFRAG urging that any 'Carve Out' of sections of IAS 39 be applicable only to banks, and then only as an option that also permits banks to use the full unmodified version of IAS 39. Our letter states that "our comments are offered in the context of seeking to help the Commission to find a way forward.

Nothing in this letter should be taken as indicative of a change in our often stated and still held position as a global organisation of support for full and immediate endorsement of the IAS 39 in the form in which it has been issued by the IASB." Click to (PDF 55k). Here is an excerpt:

We believe the best outcome would be a situation where the carve-out proposals are an option that is available only to banks, thereby achieving the Commission's objectives without exposing the standards and users in other sectors to the weaknesses and inconsistencies described in the appendix [to this letter]. Most importantly, in seeking to resolve difficulties for some banks, the Commission needs to avoid creating new difficulties for others. The Commission will be aware that whilst there are very few who would regard IAS 39 as anywhere near perfect, there are still many banks which would prefer full adoption rather than a carve-out solution. Not only does the Commission need to find a way to restrict the carve-out option to banks that need to apply hedge accounting to demand deposits, but it must also ensure that the carve-out is not made the only option available to banks. If it was to become the only option, we believe it could create as many problems for the EU banking industry as a whole as the Commission is endeavouring to solve with its carve-out proposals.

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