Stellungnahme BdB zu "Improving Disclosures about Financial Instruments - Proposed amendments to IFRS 7"
Appropriate disclosures about financial instruments will go a long way towards restoring confidence in the international financial markets. “Appropriate” in this context means that disclosure requirements are proportionate in both qualitative and quantitative terms to the risks associated with the particular instrument involved. It would not, by contrast, serve any useful purpose to introduce a large number of new requirements which would produce nothing more than an impenetrable “disclosure jungle”. We therefore welcome the fact that IFRS 7 generally links the type and scale of information to be disclosed to the intended use of the financial instrument by the entity involved and to the size of the associated risk.
Our specific comments on the planned new requirements are as follows:
We consider the fair value hierarchy proposed in para. 27A a useful format for disclosing the information required by para. 27B. Our understanding is that the introduction of the hierarchy will simply change the form of presentation, but not the measurement of individual financial instruments. We warmly welcome the adoption of the fair value hierarchy used in SFAS 157, which we believe will enhance the comparability of disclosures and advance the convergence of IFRS and US GAAP. Since the exposure draft continues to use the terminology from IAS 39 rather than SFAS 157, the Basis for Conclusions should clarify that the fair value hierarchy is permitted, and intended, to be applied and interpreted in a manner consistent with SFAS 157. Care should also be taken to ensure the greatest possible convergence between IAS 39/IFRS 7 and SFAS 157 in the course of further work on the fair value measurement project. […]