Measurement of Liabilities in IAS 37 comment letter 10 May 2010 - NFD

Deloitte Touche Tohmatsu 2 New Street Square London EC4A 3BZ United Kingdom Tel: +44 (0) 20 7936 3000 Fax: +44 (0) 20 7583 1198 www.deloitte.com Direct: +44 20 7007 0884 Direct Fax: +44 20 7007 0158 vepoole@deloitte.co.uk Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Email: commentletters@iasb.org 19 May 2010 Dear Sir David, Re: Exposure Draft ED/2010/1 Measurement of Liabilities in IAS 37 - Limited re-exposure of proposed amendments to IAS 37 Deloitte Touche Tohmatsu is pleased to comment on the International Accounting Standards Board’s (the Board’s) proposed amendments to the measurement of liabilities in IAS 37. We disagree with the Board’s decision to limit re-exposure of the revised IAS 37 to the revised measurement proposals only, and not provide constituents with an opportunity to comment on the entire draft Standard. The aspects of the proposals in the 2005 Exposure Draft to which we (and many other respondents) were strongly opposed were not limited to the measurement guidance. Furthermore, to express a view on the proposed measurement guidance in the 2010 Exposure Draft, it is fundamental that the scope, definitions and recognition criteria, to which this guidance is expected to apply, are understood. The Board made the entire draft Standard publicly available on 19 February 2010 but has given respondents no formal ...