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