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EFRAG’s overall position regarding the proposals in this ED is that:
· We do not believe the proposed disclosures are as urgently needed as the timetable implies.
· We believe the issues underlying the proposals are complex. As a result, it is questionable whether it is possible to enhance comparability between investments in debt instruments held within a single entity and also by different entities through what is essentially a ‘patch’ of existing IFRS. We are therefore not convinced that the stated objective of the proposals has been met. We also do not believe that providing more than one measure of the pre-tax profit arising from financial instruments as proposed enhances usefulness of the reported information. We believe the IASB should undertake further analysis and consideration of the issues involved. Without such a comprehensive analysis it is in our view premature to bring forward any proposals in this area or to reach any decisions on future amendments.
· Should the IASB decide to proceed with the amendments in one way or the other we recommend that they are not made mandatory for implementation in 2008 financial statements. We understand that it could be problematic for some entities to gather and analyse the information necessary to implement the proposed new disclosures in 2008 financial statements. Furthermore, backdating an effective date is problematic for jurisdictions that require legal endorsement of any changes to IFRS before they can be applied. |
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