The European Association of Co-operative Banks (EACB) gladly takes the opportunity to comment on the Basel Committee’s consultative document on guidance on accounting for expected credit losses (ECL).
As a general comment, we consider that some of the requirements laid out in the proposed guidance are extremely challenging, complex and burdensome to comply with, which will add up to the costs of complying with IFRS 9. While we understand the need to update the 2006 guidance, we believe that the provisions in IFRS 9 should be carefully considered and respected, as banks have invested important amounts in the adaptation to the new standard.
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