21 April 2015 — Consultation Response
FEE broadly agrees with the principles for banks in the guidance proposed by the Basel Committee, on accounting for expected credit losses (ECL). This consultation outlines the regulator’s expectations of implementing the new ECL model under IFRS 9 across different jurisdictions. In that regard, FEE warns that there is a fine line between proposing guidance for new international standards and intervening in standard setting or interpretation. Regulators or other bodies should thus not take the role of the International Accounting Standards Board (IASB) or of the IFRS Interpretation Committee (IFRIC). FEE firmly believes that, with the European Union’s endorsement process for IFRS 9 still pending and the on-going work of the relevant IFRS Transition Resource Group, these proposed guidelines should not be viewed as tentative interpretations of IFRS 9.