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Deloitte comment letters on liabilities

  • Deloitte Comment Letter Image

19 May 2010

Deloitte's IFRS Global Office has submitted letters of comment to the IASB on two related comment documents: Comment letter on Exposure Draft 2010/01: Measurement of Liabilities in IAS 37; Comment letter on the Working Draft IFRS: Draft IFRS Liabilities. We express an important disagreement with ED 2010/01:

We disagree with the Board's decision to limit re-exposure of the revised IAS 37 to the revised measurement proposals only, and not provide constituents with an opportunity to comment on the entire draft Standard. The aspects of the proposals in the 2005 Exposure Draft to which we (and many other respondents) were strongly opposed were not limited to the measurement guidance. Furthermore, to express a view on the proposed measurement guidance in the 2010 Exposure Draft, it is fundamental that the scope, definitions and recognition criteria, to which this guidance is expected to apply, are understood. The Board made the entire draft Standard publicly available on 19 February 2010 but has given respondents no formal opportunity to comment on other aspects of the draft Standard, which may have a bearing on the measurement guidance if adopted as proposed. In so doing, we do not believe that the Board has adhered to the spirit of due process.
We make a similar comment in our letter on the Working Draft:

We urge the IASB to consider all unsolicited comments on the sections of the working draft other than the measurement proposals. We believe that the proposed change to the recognition criteria is so significant and so inextricably linked to the measurement guidance that it cannot be understood in isolation and without putting it within the context of the entire draft Standard.

All of our past letters of comment to the IASB are Here.
Click for:
Comment letter on Exposure Draft 2010/01: Measurement of Liabilities in IAS 37
Comment letter on the Working Draft IFRS: Draft IFRS Liabilities


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