Responses to IASB Documents for Comment

IFRS 10 Consolidated Financial Statements

Exposure Draft – Effective Date of Amendments to IFRS 10 and IAS 28 – August 2015

On October 1, 2015, the AcSB submitted a comment letter responding to the IASB’s Exposure Draft issued in August 2015. The letter supports the proposal to defer indefinitely the effective date of the narrow-scope amendment, Sale or Contribution of Assets between an Investor and its Associate or Joint Venture, while retaining the ability for entities to apply the amendments earlier. Read the AcSB letter posted by the IASB.

Exposure Draft – Measuring Quoted Investments in Subsidiaries, Joint Ventures and Associates at Fair Value (Proposed amendments to IFRS 10, IFRS 12, IAS 27, IAS 28 and IAS 36 and Illustrative Examples for IFRS 13) – September 2014

On January 16, 2015, the AcSB submitted a comment letter responding to the IASB’s Exposure Draft issued in September 2014. The letter supports the clarification that the unit of account for investments within the scope of IFRS 10, IAS 27 and IAS 28 is the investment as a whole. However, the letter disagrees that the product of the quoted price of the share multiplied by the quantity of financial instruments held, or PxQ, without adjustments, should always determine the fair value of quoted investments in subsidiaries, joint ventures and associates. The letter also disagrees that PxQ, without adjustments, should always determine the fair value of the recoverable amount of a cash generating unit that corresponds to a quoted entity measured on the basis of fair value less costs of disposal. The letter observes that mandating the use of unadjusted Level 1 inputs in order to result in measurements that are objective and verifiable comes at the expense of not reflecting marketplace realities accurately. Read the AcSB letter posted by the IASB.

Exposure Draft – Investment Entities: Applying the Consolidation Exception (Proposed amendments to IFRS 10 and IAS 28) – June 2014

On September 15, 2014, the AcSB submitted a comment letter responding to the IASB’s Exposure Draft issued in June 2014. The letter supports the proposals in the Exposure Draft. The AcSB continues to think that fair value of controlled investments provides the most relevant information to the users of investment entity financial statements. The letter acknowledges that while many stakeholders consulted support the proposals, some concerns were raised by certain stakeholders. These stakeholders were concerned that applying the consolidation exception for investment entities and measuring subsidiaries at fair value may result in a lack of transparency of the underlying investments when an investment entity parent conducts all its investing activities through its subsidiaries. The letter notes that the AcSB will monitor the effect of the IFRS 10 amendments on the comparability of investment entity financial statements in Canada. Read the AcSB letter posted by the IASB.

Exposure Draft – Sale or Contribution of Assets between an Investor and its Associate or Joint Venture (Proposed amendments to IFRS 10 and IAS 28) – December 2012

On April 9, 2013, the AcSB submitted a comment letter to the IASB’s Exposure Draft issued in December 2012. The letter supports the proposals, which address the inconsistency that exists between the requirements in IFRS 10 and IAS 28 in dealing with the sale or contribution of a subsidiary by an investor to an associate or joint venture. Read the AcSB letter posted by the IASB.

Exposure Draft – Transition Guidance (Proposed amendments to IFRS 10) – December 2011

On March 20, 2012 the AcSB submitted a comment letter responding to the IASB's Exposure Draft issued in December 2011. In principle, the letter supports the proposed amendments in the Exposure Draft. However, the letter states that the proposed revisions do not clarify when an entity has relief from restating comparative financial information when it has disposed of an interest in another entity. Additionally, the letter recommends that the IASB should evaluate the need to clarify the interaction of the transition provisions in IFRS 10 with the disclosures required by IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors. Read the AcSB letter posted by the IASB.

Exposure Draft – Investment Entities – August 2011

On December 23, 2011, the AcSB submitted a comment letter responding to the IASB’s Exposure Draft issued in August 2011. The letter strongly supports the proposal that there is a class of entities (investment entities) that should report investments in controlled investees at fair value. The letter urges the IASB and the FASB to work together to develop high-quality accounting guidance for investment entities that can be applied globally. The letter recommends that some aspects of the IASB’s proposals be clarified to address practical concerns identified through consultations with Canadian stakeholders. The AcSB letter posted by the IASB is available here.