EBA欧洲银行-2010-12-16-28CEBS-comments-to-ED-2010-9-Leases29_5页_230kb

CEBS Comments on IASB Exposure Draft ED/2010/9: Leases

Core Content

The Committee of European Banking Supervisors (CEBS) has provided comments on the IASB's Exposure Draft ED/2010/9, which proposes changes to lease accounting. CEBS, composed of high-level representatives from European banking supervisory authorities and central banks, supports the IASB's goal of improving transparency and aligning lease accounting with the economic reality of lease transactions. However, the draft introduces complexities that may affect comparability and reliability of financial statements.

Main Views

• Elimination of Lease Classification: CEBS supports the removal of the distinction between operating and finance leases, as it promotes more transparent and comparable financial reporting.

• Derecognition vs. Performance Obligation: The CEBS notes that the proposed two approaches for lessor accounting—derecognition and performance obligation—reintroduce complexity and scope for judgment. They suggest that a single criterion based on the transfer of "significant risks and benefits" should be used instead of the concept of "control."

• Consistency and Principle-Based Approach: CEBS recommends that the standard should clarify that the accounting treatment is not optional but depends on the lessor's exposure to significant risks and benefits. This would lead to a more consistent and principle-based approach.

• Double Counting of Assets: CEBS highlights the need to ensure that the treatment applied by the lessor and lessee does not result in double counting of the same asset.

• Judgment and Complexity: The CEBS is concerned about the high level of judgment required in determining lease terms, contingent rentals, and other optionalities, which could reduce the reliability and comparability of financial statements.

• Revaluation of Right-of-Use Asset: CEBS questions the proposed option for lessees to revalue the right-of-use asset for each class of property, plant, and equipment, as it may impair comparability and introduce volatility in equity. They suggest that this option should be reconsidered.

• Short Term Leases: CEBS welcomes the less onerous treatment for short term leases but believes that the proposed approach may not provide sufficient relief. They suggest that the standard should consider the economic substance of lease contracts to determine if they qualify for short-term treatment, and recommend that entities should evaluate the cost/benefit ratio of such contracts.

Key Information

• Contact: CEBS comments were coordinated by the Expert Group on Financial Information (EGFI), chaired by Mr. Didier Elbaum, and the Subgroup on Accounting under the direction of Mr. Michel Colinet. Contact details are provided for further inquiries.

• Appendix: The appendix contains detailed comments on various aspects of the Exposure Draft, including the scope of the standard, lessor and lessee accounting, lease term and optionalities, and short term leases.

• Comparability and Reliability: CEBS emphasizes the importance of maintaining comparability and reliability in financial statements, suggesting that the IASB should explore ways to simplify the standard and reduce the scope for judgment.

• Converged Standards: CEBS encourages the IASB and FASB to continue developing a single set of high-quality converged lease accounting requirements, which would benefit investors and users globally.

Recommendations

• Clarify the accounting treatment based on the transfer of significant risks and benefits.
• Avoid the use of judgment in determining lease terms and other optionalities.
• Consider the economic substance of lease contracts when determining their classification.
• Reconsider the revaluation of right-of-use assets for lessees.
• Explore further simplifications for short term leases, including materiality-based criteria.