Deloitte comment letter on the IASB's proposed amendments to IFRS 9

Published on: 24 May 2017

We have responded to the IASB's Exposure Draft 2017/3, Prepayment Features with Negative Compensation (Proposed amendments to IFRS 9) that was published in April 2017.

We agree with the amendments proposed in the exposure draft but have concerns with the approach taken in the proposals:

  • We are not supportive of the inclusion of a criterion requiring the prepayment feature to have an insignificant fair value at initial recognition.
  • We have concerns with the way the amendment is structured and drafted in that the Basis for Conclusions on the ED appears to add further interpretative material on what is 'reasonable additional compensation'.

Download the full comment letter below.

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