We comment on fair value measurement ED

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29 Sep 2009

Deloitte Touche Tohmatsu has submitted comments on the IASB Exposure Draft Fair Value Measurement, which was published 28 May 2009. We are generally supportive of the proposal, though we have concerns about some aspects and make suggestions for changes.

The ED proposes guidance on how fair value should be measured where it is required by existing standards. The ED does not propose to extend the use of fair value measurements in any way. It would add disclosure requirements about how fair values were determined. If adopted, the proposals would replace fair value measurement guidance contained within individual IFRSs with a single, unified definition of fair value, as well as further authoritative guidance on the application of fair value measurement in inactive markets. The IASB's starting point in developing the exposure draft was the equivalent US standard, SFAS 157 Fair Value Measurements (now Accounting Standards Codification Topic 820). The proposed definition of fair value is identical to the definition in SFAS 157, and the supporting guidance is also largely consistent with US GAAP. You will find an overview of the Proposals in the ED Here.

An excerpt from our letter of comment on the ED: We support the Board's efforts to replace the existing guidance on fair value measurement in IFRS accounting literature with a single standard and strive for closer convergence with fair value measurement requirements in Accounting Standards Codification Topic 820 (ASC 820) Fair Value Measurements and Disclosures (formerly Statement 157), issued by the US Financial Accounting Standards Board (FASB). Global convergence is important as it serves to further reduce complexity and application issues that often result from inconsistent principles in similar US and international standards. Moreover, convergence of this draft IFRS will result in more consistent measurement of fair value among IFRS preparers and better comparability with entities preparing financial statements under US GAAP. Furthermore, we understand that full convergence to ASC 820 may not be appropriate in instances where the IASB ED has demonstrated a more conceptually superior principle. However, in areas where the IASB does agree with the principles in ASC 820, we recommend the verbiage be closely aligned as not to create wording differences that cause confusion among constituents....

Some proposals within the ED do not move the draft IFRS towards convergence and, we believe, have not been demonstrated to be conceptually superior to ASC 820. For example, such proposals include, but are not limited to, the most advantageous market concept, the definition of a 'knowledgeable' market participant, and the accounting (deferral) of certain day one gains and losses.

Click to download Our Comment Letter (PDF 126k). All past comment letters are Here.


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