From: rainer.krauser@dzbank.de
Sent: Friday, September 29, 2006 9:42 AM
To: Svetlana Pereverzeva
Cc: yvonne.donkoff@dzbank.de
Subject: comments on EFRAG draft comment letter on ED of Amendments to
IAS 32 and IAS 1 Financial Instruments Puttable at Fair Value



Dear Ms. Pereverzeva,

we agree with EFRAG'S comments on IASB's ED of Amendments to IAS 32 and IAS 1. 
Especially, we welcome that EFRAG's comment letter emphasises the fact that 
there is a large number of cooperatives and partnerships which issue 
simmular instruments than those within the scope of the ED which are 
not puttable at fair value. As EFRAG'S letter correctly points out, 
such instruments should also be classified as equity.

We hold the position that there should be a definition of equity 
that serves all types of companies by respecting the diversity of member 
shares, ownership rights and capital structures and thus providing for 
fair competition on the international capital market.

Kind regards
Rainer Krauser
DZ Bank AG
Consultant
Financial Accounting
RWZK
Platz der Republik
D-60265 Frankfurt
Phone 0049 69 7447 4864
mailto Rainer.krauser@dzbank.de