From: Desmond Wright [Desmond.Wright@icaew.co.uk]
Sent: Wednesday, October 04, 2006 12:09 PM
To: Svetlana Pereverzeva
Subject: RE: Financial instruments puttable at fair value

Svetlana

Thank you for your email.  We very much appreciate the opportunity to engage.

We oppose the proposed amendments, and I do not think we would support them even 
if the scope was widened to give relief to relevant entities in European countries, 
because they are unprincipled and will lead to inconsistent and anomalous reporting.  

Having said that, we accept that EFRAG's proposal to widen the scope is a fall-back 
position that could benefit European constituents, and as such we do not object 
to the content of your draft letter.  But we are very clear that we do not 
see widening the scope as the solution.  It will still not be a principles-based 
amendment and the anomalous accounting would remain. Furthermore, all such a 
widening of the scope will do is to confirm the view that this is merely a 
means of presenting a liability in equity. It will not mean that these instruments 
will be considered true equity and the onerous disclosure requirements will 
not be removed.

Please do get back to me if I can be of any further help.

Regards

Des







-----Original Message-----
From: Svetlana Pereverzeva [mailto:Svetlana.Pereverzeva@EFRAG.ORG]
Sent: 03 October 2006 15:44
To: Desmond Wright
Subject: Financial instruments puttable at fair value


Dear Desmond,

Thank you very much for the comment letter.  I appreciate the fact that
you are still finalising your detailed views on the ED but I need to
finalise analysis of the comments received by the end of tomorrow and
therefore would like to clarify one point.  

You wrote to us that you are generally content with EFRAG's draft letter
and then state that you do not support the amendments proposed by the
IASB.  EFRAG's letter, states that EFRAG disagrees with this ED BUT if
notwithstanding our arguments the amendments are implemented EFRAG
suggested widening the scope to address similar issues of the European
constituents.  Do you agree with the comments after BUT?  

Thank you very much in advance.  
Kind regards,

Svetlana.  

-----Original Message-----
From: Desmond Wright [mailto:Desmond.Wright@icaew.co.uk] 
Posted At: Monday, October 02, 2006 11:31 AM
Posted To: Puttable instruments
Conversation: Financial instruments puttable at fair value
Subject: Financial instruments puttable at fair value

Dear Sir

I attach the comments of the Institute of Chartered Accountants in
England and Wales on EFRAG's draft letter about the proposed amendments
to IAS 32

Yours faithfully

Desmond Wright

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