We comment on leases discussion paper

  • Deloitte Comment Letter Image

18 Jul 2009

Deloitte has submitted comments on the IASB discussion paper Leases: Preliminary Views.

While we acknowledge the need for an improved leases standard issued identically by the IASB and the FASB, the views of individuals within the DTT network differ on what is the best way forward. Some individuals believe strongly that, should the boards decide that the recognition of all leases 'on balance sheet' is critical in the short term, the boards should focus on lessee accounting only (as well as the limited lessor accounting issues that must be addressed as part of lessee accounting, such as subleases). Other individuals within the DTT network have significant concerns about the boards issuing a leasing standard in the short-term that is neither high-quality nor comprehensive. Because of those concerns, those individuals are not in favour of the boards focusing on lessee-only issues and believe strongly that the boards should take the necessary time to develop a comprehensive leasing standard that addresses all issues for both lessee and lessor accounting. Below is an excerpt from our letter. Click to download Our Letter of Comment (PDF 102k). All past letters comment are Here.

We have spent a considerable amount of time discussing this issue and reached out to many professionals within the DTT network to gather thoughts about how the boards should best move forward with this project. In so doing we have, through our network, also received comment from various external organisations having experience in this area which have helped us form our views. Many have expressed concern about the significant cost and effort that will be required to apply the proposed model, particularly system changes and procedures that will need to be put in place....

We continue to be very supportive of the convergence efforts between IFRS and U.S. GAAP around high quality standards and believe the boards should be working together on an improved high-quality lease standard. However, we are concerned that many of the preliminary views of both boards differ. We believe it is very important to have one set of high-quality global standards. Besides creating a truly level playing field for companies around the globe, having a single set of standards will eliminate the potential for accounting arbitrage between U.S. GAAP and IFRSs. Therefore, we believe that the IASB and FASB should issue identical standards on leasing and all other future convergence standards.

We do not consider lease accounting to be a high priority project at this very important time, when the boards' attention should be focussed on resolving other, urgent issues arising from the financial crisis, for example the financial instruments project. We therefore urge the boards to consider their priorities carefully.


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