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ISCA comments on IASB’s ED Interest Rate Benchmark Reform (Proposed amendments to IFRS 9 and IAS 39)

We broadly support and agree with IASB’s proposals in the ED except for the following concerns:

  • need for expedition of the Board’s work relating to phase two
  • principle on when to cease the application of reliefs is unclear
  • lack of clarity on what entities should do in the event of a failure of retrospective assessment due to mismatch between the hedged item and the hedging instrument
  • limited circumstances for retrospective application of proposed amendments
  • potential risk of having to terminate hedging relationships due to inability to complete hedge documentation in a timely manner

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