PwC appreciates the International Valuation Standards Council (IVSC) Standards Board (board) efforts and welcomes the opportunity to provide comments on the exposure draft (ED) that sets out the board’s proposals aimed at providing information on credit and debit valuation adjustments. Our comment letter outlines our general comments to the proposal and responds to certain specific questions for comment in the appendix.
In this comment letter, we respond to the boards tentative agenda decision: IFRS 2, Share-based payment – price difference between the institutional offer price and the retail offer price for shares in an initial public offering. We support the committee’s decision not to take this question onto the agenda but not for the reasons given. We are concerned that the reasons given for the agenda decision will increase diversity in practice regarding the application of IFRS 2 paragraph 13A and may also lead to diversity in the application of IFRS 13.
In this comment letter, we do not object to the board’s proposal to restore the use of the equity method as one of the options to account for investments in subsidiaries, joint ventures and associates in an entity’s separate financial statements. However, we do not support the requirement for retrospective application of the exposure draft nor the proposed consequential amendment to IAS 28, Investments in Associates and Joint Ventures.
While overall we agree with ASEC’s proposed restructuring and revised TSP and Criteria exposure draft, within our response we specifically highlighted and provided examples where some criteria could be further enhanced.
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 fully supports efforts to enhance financial reporting for private companies, and believes that the most appropriate way to achieve meaningful change for private company stakeholders is through the collaborative efforts of the recently established Private Company Council (PCC) and the FASB. However, should the AICPA decide to issue this new non-GAAP framework, our comment letter provides observations and recommendations on changes the AIPCA should make to minimize confusion and enhance clarity. ...
PwC agrees with the proposed change to limit the disclosures to derivatives, repurchase agreements and reverse repurchase agreements, and securities borrowing and securities lending transactions that are either offset or subject to a master netting arrangement or similar agreement.
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.
PwC supports the PEEC's stated objective of clarifying the circumstances under which the AICPA Code of Professional Conduct applies to services provided by its members. PwC recommends that prior to adopting its proposal, the PEEC should further consider three things: (1) whether the PEEC's proposed revision to the definition of professional services will have the unintended effect of sweeping in services that have no connection with or relationship to the practice of accountancy; ...
PwC encourages the Board to continue its outreach to investors and other stakeholders as it decides which alternatives to proceed with and develops them into a proposal. PwC generally supports the Board's effort to improve the relevance and comparability of financial reporting by developing a framework for setting disclosure requirements.
PwC generally believes that the draft framework identifies the appropriate matters to consider when determining whether a modification is appropriate. It identifies the significant differentiating factors that could support financial reporting differences between public and private companies.
PwC supports the proposal to provide information about the impact of reclassifications from accumulated other comprehensive income to net income in a single footnote. Most of the information to be disclosed is already included elsewhere in the financial statements. Consolidating it and providing a roadmap to the related disclosures will provide users with improved information without the operational challenges and costs that would have resulted from requiring separate presentation on the face of the income statement of the effects of the reclassifications on individual line items, particularly when such information is not readily available.
PwC suggests enhancements to the proposed guidance in the event that others believe it will be helpful to preparers and financial statement users and will improve consistency as to when and how to prepare financial statements using the liquidation basis of accounting.
PwC agrees that improved disclosures about liquidity and interest rate risks could provide a deeper understanding of an entity's risk profile. While the Firm encourages the Board to continue its outreach to analysts and preparers as it further develops the proposed disclosures, it offers a number of recommendations for the Board's consideration.
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 generally supports the proposals and believes they will heighten the auditor's focus on the potential for material misstatement, particularly material misstatement due to fraud, arising from relationships and transactions with related parties, significant unusual transactions, and financial relationships and transactions with executive officers.
PwC believes that the audits of brokers and dealers should be conducted in accordance with PCAOB auditing and attestation standards once the SEC adopts Rule 17a-5 and, therefore, supports the changes to the Board's rules to reflect its pending jurisdiction over the auditors of brokers and dealers.
PwC commends the Board for issuing a re-proposal of the proposed standard and appreciate the Board's responsiveness in considering, addressing and providing feedback with respect to comments received on the original proposal. In the letter, PwC respectfully offers some suggestions that it believes will further improve the proposal.
PwC provides its perspective on the rules to be reviewed in accordance with the requirements of the Regulatory Flexibility Act. PwC's comments are focused on auditor independence requirements approved by the SEC in November 2000, highlighting areas where the firm believes those rules may have a detrimental impact on small companies, investors and the U.S. capital markets.
PwC global network of firms believes that the time is right to significantly enhance auditor reporting. Valuable enhancements can be made now that move us some way to achieving the goal of more informative and valuable auditor reporting. As solutions are developed, it is critical that there be active, continuous and open dialogue amongst auditing standard setters, regulators, users and other stakeholders. PwC global network urges the IAASB to work in collaboration with the PCAOB in relation to their respective consultation papers to develop solutions that work globally.
PwC global network of firms believes that the proposed standard provides a strong basis for the performance of all assurance engagements and will facilitate consistent high quality engagements, capable of being supplemented by clearly tailored topic-specific ISAEs as required, in response to the needs of users. PwC global network also believes that the revisions to the requirements and application material to better articulate the defining characteristics of a limited assurance engagement, together with the principles and differences between attestation and direct engagements, are useful.