Stellungnahme der DK zum Exposure Draft "Classification and Measurement: Limited Amendments to IFRS 9" (ED/2012/4)

27. März 2013

Our basic opinion is as follows:

  • We welcome the principle-based rules of IFRS 9.
  • IFRS 9 should enable an appropriate reflection of the business models of banks and should consider the management of banking transactions on a portfolio basis.
  • We advocate drafting the FVTOCI category as an optional category.
  • We consider 2015 to be unrealistic for first-time application as proposed by the IASB.
  • We would strongly welcome greater dialogue between the IASB and regulators.

With this Exposure Draft, the IASB has picked up on various points of criticism regarding the already finalised IFRS 9 (2009/2010). The key change is the proposed introduction of the FVTOCI category. The IASB has stated that such a category would avoid differences to US GAAP rules and that measurement or recognition inconsistencies would be reduced for insurance companies.

The introduction of an FVTOCI category is seen by insurance companies to be an improvement compared to IFRS 9 (2009/2010). However, it is not yet possible to estimate how IFRS 4 and IFRS 9 will interact because IFRS 4 will not be finalised for a number of years. For banks, however, the IASB's proposed introduction of an FVTOCI category could result in problems with a view to the appropriate reflection of the business model in financial statements due to the unclear distinction between AC and FVTOCI. There is hence a conflict of goals between the banking sector and the insurance sector. […]

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