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We comment on proposed IFRS 7 exemption

  • Deloitte Comment Letter Image

20 Dec 2009

Deloitte has submitted a comment letter on Exposure Draft ED/2009/13 Limited Exemption from Comparative IFRS 7 Disclosures for First-time Adopters.

The ED proposes to amend IFRS 1 First-time Adoption of IFRSs to state that an entity need not provide the comparative prior-period information required by the March 2009 amendments to IFRS 7 Improving Disclosures about Financial Instruments for first-time adopters adopting before 1 January 2010. We support the amendments proposed in the Exposure Draft. However, the need for this amendment raises a concern about the Board's haste in its due process (see box below). Click to Download our Comment Letter (PDF 17k). 

We would also like to highlight the fact that in our view the Exposure Draft suggests a lack of rigor taken by the Board in preparing the original consequential amendments to IFRSs made necessary by the amendment to IFRS 7 issued in March 2009. We continue to be concerned that the combined effect of ambitious deadlines, shortened periods for comments and deliberations, as well as the heavy workload on the Board's agenda means that this and potentially other consequential amendments fail to be identified at the appropriate time, resulting in precious Board time being spent fixing problems that could have been identified had greater attention to such matters been paid originally.


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