31 August 2009
Sir David Tweedie
Chairman
International Accounting Standards Board
30 Cannon Street
London EC 4M 6XH
UNITED KINGDOM
commentletters@iasb.org.uk
Dear Sir David
ED2009 Credit Risk in Liability Measurement
The Group of 100 (G100) is an organization of chief financial officers from Australia’s largest business enterprises whose primary purpose is to advance Australia’s financial competitiveness.
| Q1 |
When a liability is first recognized, should its measurement (a)
always, (b) sometimes or (c) never, incorporate the price of credit risk
inherent in the liability? Why? a. If the answer is ‘sometimes’, in what cases should the initial measurement exclude the price of the credit risk inherent in the liability? b. If the answer is ‘never’ (i) what interest rate should be used in the measurement? (ii) what should be done with the difference between the computed amount and cash proceeds (if any)? The G100 believes that
whether credit risk is taken into the measurement will depend on the
nature of the financial instrument and the basis upon which it is
measured. For example, credit risk will be one of the factors reflected
in the measurement of a financial instrument recognized at fair value
and as such credit risk is included in the measurement on initial
recognition. Where an instrument is measured on a cost basis and
recovery/settlement of cost is expected, credit risk will not be
included in the measurement. However, credit risk would have been a
factor influencing the terms and conditions (contractual interest rate)
relating to the instruments. |
| Q2 |
Should current measurements following initial recognition (a) always,
(b) sometimes or (c) never, incorporate the price of credit risk
inherent in the liability? Why? If the answer is ‘sometimes’, in what
cases should subsequent current measurements exclude the price of the
credit risk inherent in the liability? The term ‘current
measurements’ implies the use of fair values. As indicated above, credit
risk is one of the factors influencing the measurement in a fair value
model. |
| Q3 |
How should the amount of a change in market interest rates
attributable to the price of the credit risk inherent in the liability
be determined? A difficulty in these cases is how to determine the
extent to which changes in credit risk have affected market interest
rates. While estimates based on the spread between risk free rates and
the transaction rate, credit default swap rates and analysis by credit
agencies there are likely to be concerns about the degree of
subjectivity and arbitrariness involved and its effect on the
reliability of the information. There may also be difficulties in
separating the credit risk relating to a particular instrument from that
relating to the entity as a whole. |
| Q4 |
The paper describes three categories of approaches to liability
measurement and credit standing. Which of the approaches do you prefer
and why? Are there other alternatives that have not been identified? The G100 would support the so-termed frozen spread approach on the grounds that it is consistent with the definition of fair value and is consistent with the practice of entities seeking to achieve certainty of funding costs by locking in the initial position to have protection from interest rate charges. As indicated above, where an instrument is measured at fair value the credit risk relating to the instrument will be impacted in its valuation and seeking to remove its effect would be futile. |
Yours sincerely
Tony Reeves
National President