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Deloitte comment letter on ED/2009/3 'Derecognition'

Published on: 30 Jul 2009

We support the objective of the ED to change the existing derecognition requirements in IAS 39 to a more robust model based on a single principle for derecognising financial assets.

Overall, however, we do not support the model proposed in the ED, rather our preference is for a modified alternative approach that in some respects is a combination of the proposed approach and the alternative approach described in the appendix to the ED. Our preferred approach is closer to the alternative approach with the significant difference that if a transferor retains control over certain rights to cash flows under the transferred asset that those cash flows are not included in the derecognition assessment, i.e. they continue to be recognised.

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