July 8 2013

Comments by the German Banking Industry Committee on ED/2013/3 Financial Instruments: Expected Credit Losses

The German Banking Industry Committee welcomes the proposed expected credit loss approach submitted by the IASB which fundamentally addresses the widely criticised shortcomings of the incurred loss model. In this regard, we support the IASB’s credit deterioration approach, which differentiates between high quality loans and loans of lower and worsening credit quality (“good book” versus "bad book” assets).

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