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

Impairment of Financial Assets

The Group of 100 (G100) is an organization of chief financial officers from Australia’s largest business enterprises with a purpose of advancing Australia’s financial competitiveness. The G100 is pleased to provide input to the Request for Information.

The G100 commends the IASB’s initiative to seek the views of constituents on a controversial issue to assist it in forming views to be included in an exposure draft. This is a welcome development and we believe that this form of consultation with constituents should be embedded as a regular feature of the IASB’s due process because it enables the IASB to be aware of practical considerations of proposals when developing an exposure draft.

The relative merits of the incurred loss and expected loss approaches to determining impairment of financial assets are likely to differ depending on the nature of an entity’s activities. Implementing the expected loss approach is likely to have the most significant operational impacts and costs on entities engaged in financial activities, in particular, the need to be continuously assessing financial assets for impairment.

The G100 has consulted with the Australian Bankers Association and supports the views expressed in its submission to the IASB.

Yours sincerely

Tony Reeves
National President