FEE's response to the draft EFRAG comment letter on IASB Exposure Draft ED/2012/4 Classification and Measurement: Limited Amendments to IFRS 9 (proposed amendments to IFRS 9 (2010)) supports the direction of the proposals but agrees with many of EFRAG's concerns.  The letter goes on to note the following:

Given the current scheduled timing of the IFRS 9 phases, we believe the current mandatory application date of 2015 is no longer realistic. Taking into account the complexity and the number of changes expected to the accounting systems and processes, we continue to believe that at least 24 months implementation period should be envisaged to allow for a well-managed practical and effective implementation.

The letter also notes "the counterintuitive result of the current treatment of ‘own credit’ should be resolved as soon as possible", suggesting an amendment to IAS 39 Financial Instruments: Recognition and Measurement.

Click for the full comment letter (link to FEE website).

FEE has also publicly released its response (link to FEE website) to EFRAG's draft comment letter on the proposed limited scope amendments to IAS 28 Investments in Associates and Joint Ventures (2011) contained in IASB Exposure Draft ED/2012/3 Equity Method: Share of Other Net Asset Changes.  FEE does not support the proposals in ED/2012/3 "since they are inconsistent with some of the concepts of other IFRSs" and suggests the IASB "should further consider conceptual solutions to the existing difficulties in the application of the equity method of accounting more broadly before final conclusion is reached".