9. February 2016
Yesterday, the ASCG submitted its comment letter on the ED/2015/11 Applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts to the IASB.
The ASCG agrees that there should be both, the overlay approach and the temporary exemption from applying IFRS 9, since the benefits of the particular approaches depend on the specific facts and circumstances of the entity.
However, the ASCG points out in its comment letter that for the German jurisdiction all are striving for the deferral approach, as only this approach addresses the respective situations of the entities.
In general, the ASCG agrees with most of the specific provisions suggested in the ED and only suggests minor amendments to the proposals.