We agree that IFRS 9 and IAS 39 should be amended in anticipation of interest rate benchmark reform and we support the approach to amending those standards which the IASB have taken in the ED. However, we believe the end of application proposals should be further clarified. Detailed end of application requirements are unusual in standard setting documents. We agree that they are required in this particular case, but in order to provide clarity and ensure they are applied consistently, illustrative examples should be added to the final amendments to the standards, covering all the main scenarios which are likely to arise in practice for companies which apply hedge accounting in their financial statements. In our view, these scenarios are not limited to those described in scenarios A-E in paragraphs BC35-BC40 of the ED. In this context, please see our detailed responses below.

See detailed response (pdf)

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