The PwC global network of firms expresses support of the proposed interim standard on regulatory deferral balances. The interim standard will help resolve practice problems in some jurisdictions and reduce the barriers to adopting IFRS, but will not increase diversity in practice among entities that already apply IFRS. Our letter also provides responses to the board's specific questions.
In this comment letter, the PwC global network of firms responded to the IASB’s exposure draft on Financial instruments: Expected credit losses. The PwC global network continues to support the development of a single converged model for credit impairment under both IFRS and US GAAP. We believe an expected loss approach that requires constituents to consider a broader information set, including future expectations, represents a significant improvement as compared to the incurred loss model used today.
The PwC global network of firms supports the board’s efforts to gather information on the topic of rate regulation and provides suggestions for the board to consider for the discussion paper phase of the project.
PwC supports the board’s efforts in clarifying whether an entity is required to discontinue hedge accounting when an over-the-counter (OTC) derivative is novated to a central counterparty (CCP) as required by law or regulation. We also appreciate the board’s responsiveness in addressing this urgent issue in a pragmatic way, as requiring entities to treat such novations as a discontinuance of hedge accounting would not provide useful information to investors.
PwC agrees with the board’s objectives to amend IFRS 9 and commend the board on their progress in achieving those objectives. The letter includes key comments that we would like to raise with the board.
Following consultation with members of the PwC network of firms, this response summarizes the views of member firms who commented on the tentative agenda decision, published in the January 2013 edition of IFRIC Update.
PwC global network of firms submitted comments on the IASB's request for information on IFRS for SMEs. The comments provided have been grouped into six broad categories to simplify our response and to avoid repetition. The Firm comments specifically on the scope of the SME standard, convergence with IFRSs, income taxes, options, convergence with the EU directives and the use of additional IASB guidance for SMEs.
The PwC network global network of firms believes that the application of the conclusions in the draft interpretation will result in accounting that does not reflect the economic substance of many levies.
PwC global network of firms supports the Interpretations Committee's decision that the accounting for employee benefit plans with a promised return on contributions or notional contributions explored in the Draft IFRIC should be further considered.
PwC global network of firms agrees with the relief provided in the exposure draft with regards to the transition guidance in IFRS 10. However, the firm believes that the effect of the BoardÆs proposed relief is complicated to implement in practice. ...
PwC global network of firms welcomes the IASB's approach to provide differentiated fair value reporting for qualifying investment entities. The Firm, however, is concerned that there are significant differences between the IASB and FASB's respective proposals. The Firm believes that the Boards' differing approaches to the treatment of a controlling financial interest in an investment entity by a non-investment entity parent should be eliminated.
PwC global network of firms provides detailed responses to the questions included in the Agenda Consultation. The Firm also notes some of the broader issues that it believes the Trustees and the IASB should consider when establishing the agenda of the IASB.
PwC global network of firms strongly believes that the Implementation Group should not issue a Q&A that addresses the interpretation of "undue cost or effort" and/or "impracticable." The Firm believes that the SMEIG should not address through Q&As issues that might be relevant to full IFRS. The Firm notes that the SMEIG might use the "basis for conclusions" in the Q&As to limit the scope of the non-mandatory guidance, but there remains a danger that the Q&As might be considered in the interpretation of full IFRS, particularly in areas in which there is no guidance in full IFRS.