Stellungnahme BdB zum Entwurf des IASB "Investments in Debt Instruments - Proposed amendments to IFRS 7"

16. Januar 2009

We welcome the disclosure of high-quality, detailed information in the notes. Care should nevertheless be taken to avoid information overkill. This would actually lead to less transparency because potentially relevant information would be more difficult to identify or would even risk getting lost altogether in the resulting "disclosure jungle". The disclosures proposed by the IASB would not reflect management intent Furthermore, there is a danger that the disclosure of certain data might paint a distorted picture of the entity's situation and thus mislead the users of financial reporting.

We have very serious reservations about the proposed introduction of additional fair value information for debt instruments which are not recognised at fair value in profit or loss. We reject the proposal to require entities to disclose what the impact on pre-tax results would be if all debt instruments were measured at fair value. This would do nothing to solve the existing problems. The classification and thus the measurement of financial instruments depend on the business models and holding strategies associated with the particular instrument in question (management intent). The fact that financial instruments in the loans and receivables and held-to-maturity categories are not reported at fair value implies that the entity's management does not intend to realise short-term gains resulting from market fluctuations. […]

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