Comment letter ED IFRS 7 amendments DRAFT

International Accounting Standards Board 30 Cannon Street Grant Thornton International London Regent's Place EC4M 6XH 7th Floor 338 Euston Road London NW1 3BG 15 December 2008 Submitted electronically through the IASB Internet site (www.iasb.org) Exposure Draft Proposed Amendments to IFRS 7 Financial Instruments: Disclosures Grant Thornton International is pleased to comment on the International Accounting Standards Board's (the Board) Exposure Draft Improving Disclosures about Financial Instruments: Proposed Amendments to IFRS 7 (the ED). We have considered the ED, as well as the accompanying draft Basis for Conclusions. We support the direction of the proposals. We have a concern over the impact of the proposed effective date when considered in conjunction with retrospective application of the amendments. We have also identified a small number of areas where we believe the disclosure burden could be eased somewhat without detracting from the usefulness of the information provided. In addition, we have suggestions for expressing certain of the proposed amendments more clearly. We elaborate on these comments and suggestions and respond to the questions in the ED's Invitation to Comment in the following paragraphs. Fair value disclosures Question 1 Do you agree with the proposal in paragraph 27A to require entities to disclose the fair value of financial instruments using a fair value hierarchy? If not, why? We agree with the ...