EBA欧洲银行-2009-04-0928CL-DP-Financial-Statement-Presentation29_8页_114kb

CEBS Summary on Preliminary Views on Financial Statement Presentation

Core Content

The Committee of European Banking Supervisors (CEBS) has provided feedback on the IASB's Discussion Paper (DP) titled "Preliminary Views on Financial Statement Presentation." CEBS, composed of high-level representatives from banking supervisory authorities and central banks across the European Union, emphasizes the importance of high-quality, transparent, and comparable financial statements for the banking and financial industry.

Main Concerns and Key Points

1. Usefulness and Relevance of Proposed Presentation

• CEBS questions the usefulness and relevance of the proposed financial statement presentation for banks.
• They are unsure whether the current classification of most assets and liabilities under the operating category will improve clarity or meaning.
• CEBS recommends further consultation with financial institutions to ensure the final format is user-friendly and relevant.

2. Comparability and Clarity

• CEBS is concerned that the proposed format may reduce comparability across financial institutions.
• They believe that the guidance as drafted may lead to inconsistencies in the classification of activities, which could obscure key financial metrics.
• A decrease in comparability is seen as particularly problematic in the current regulatory environment.

3. Comprehensive Income Statement

• CEBS supports the distinction between net income and other comprehensive income.
• They caution against the loss of this distinction if a single statement of comprehensive income is imposed.
• They also question the benefits of the proposed format, arguing that the gains in cohesiveness do not outweigh the potential loss in comparability.

4. Disaggregation and Materiality

• CEBS agrees that increased disaggregation can improve the usefulness of financial statements.
• However, they warn against excessive granularity that may obscure key metrics and reduce comparability.
• They support the approach used in their FINREP framework, which is consistent with IFRS but tailored for prudential reporting.

5. Reconciliation Schedules

• CEBS acknowledges the value of the proposed reconciliation schedule but raises concerns about its complexity.
• They suggest that simpler disclosures might be more cost-effective and useful.
• CEBS believes that the transparency of fair value changes is important and should be achieved through separate presentation.

6. Future Disaggregation of Fair Value Changes

• CEBS supports the idea of further disaggregation of changes in fair value but believes it should be addressed through disclosures rather than the reconciliation format.
• They recommend that the IASB revisit the cost-benefit analysis with field trials involving financial institutions.

7. Alternative Reconciliation Formats

• CEBS suggests that alternative formats, such as the statement of financial position reconciliation or the comprehensive income matrix, could be considered.
• However, they believe these formats are too complex and not relevant for banks, which are more focused on cash flows.

Summary of Key Recommendations

• Further consultation with financial institutions is necessary to ensure the proposed format is useful and relevant.
• Cost-benefit analysis should be expanded, especially through field trials, to assess the impact of proposed changes.
• Clarity and comparability should be prioritized over increased disaggregation.
• The distinction between net income and other comprehensive income should be retained.
• Reconciliation schedules should be simplified to avoid unnecessary complexity and costs.
• Disaggregation of fair value changes should be considered in future projects, preferably through disclosures.
• Alternative reconciliation formats may be useful for certain industries but should not be mandated for banks.

Conclusion

CEBS values the IASB's efforts to improve financial reporting and disclosure, but they emphasize the need for a careful balance between transparency, comparability, and practicality. They urge the IASB to consider the unique needs of financial institutions, particularly banks, and to ensure that any changes to financial statement presentation are both useful and cost-effective.