Deloitte comment letter on ED 'Amendments to IAS 39 Financial Instruments: Recognition and Measurement - The Fair Value Option'
We believe the Proposed Amendment diverges from a principle-based approach to a set of arbitrary rules. In addition, the basis for the proposed rules is unclear, which creates the potential for differing interpretations that are not consistent with the Board’s intent.
We also believe the introduction of a new “verifiability” measurement standard as a condition for using the fair value option will raise numerous implementation issues. We do not believe the Proposed Amendment is an ideal or workable solution.