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48<br />

Financial Reporting<br />

The FRC recognises that<br />

additional guidance in FRS 102<br />

is desirable on how to determine<br />

whether an entity is acting as a<br />

principal or an agent, and FRED 67<br />

proposes to add such guidance based<br />

on IAS 18 Revenue.<br />

Recent IFRS standards<br />

Perhaps equally important to the<br />

proposals to change FRS 102 being<br />

made by the FRC is the fact that<br />

FRED 67 is not proposing to fasttrack<br />

the more recent new IFRS<br />

standards into FRS 102, such as IFRS<br />

15 on revenue, IFRS 16 on leases and<br />

the expected loss model of IFRS 9.<br />

FRED 67 states that these will be the<br />

subject of a later consultation by the<br />

FRC and will not be effective before 1<br />

January 2022.<br />

The FRC also considered whether<br />

to incorporate into FRS 102 the<br />

updated rules of IFRS on how to<br />

identify when one entity controls<br />

another, as set out in IFRS 10<br />

Consolidated Financial Statements.<br />

The FRC decided not to propose<br />

changing this aspect of FRS 102.<br />

However, FRED 67 recognises that<br />

this may result in certain structured<br />

or special purpose entities not being<br />

consolidated under FRS 102 and<br />

proposes that additional disclosures<br />

about such entities should be<br />

included in the accounts.<br />

Financial instruments: accounting<br />

and disclosure<br />

A major feature of FRS 102 is the<br />

choice it offers on accounting for<br />

financial instruments and the<br />

financial institutions it requires<br />

to give enhanced disclosures on<br />

financial instruments.<br />

Under FRS 102, preparers can<br />

choose whether to apply Sections<br />

11 and 12 of FRS 102, or IAS 39, or<br />

IFRS 9 in accounting for financial<br />

instruments. The FRC had to<br />

consider how FRS 102 should deal<br />

with these choices as the effective<br />

date of IFRS 9, as the replacement<br />

for IAS 39, draws nearer. FRED 67<br />

proposes that the three options<br />

should be retained in FRS 102 and<br />

specifies which version of IAS<br />

39 should be used where the IAS<br />

39 option is chosen. As a futureproofing<br />

measure, FRED 67 proposes<br />

that the version of IAS 39 to be<br />

used is the version that is effective<br />

at the preparer’s year-end date,<br />

The Financial Reporting Council recognises<br />

that additional guidance in FRS 102 is desirable on how<br />

to determine whether an entity is acting as a principal<br />

or an agent, and FRED 67 proposes to add such<br />

guidance based on IAS 18 Revenue.<br />

and proposes that, when IAS 39 is<br />

superseded by IFRS 9, the relevant<br />

version of IAS 39 will be the one<br />

that was effective at the date it was<br />

superseded by IFRS 9.<br />

As well as proposing an<br />

amendment to the definition of a<br />

financial institution under FRS 102,<br />

which will reduce the number of<br />

such institutions required to provide<br />

enhanced disclosures, FRED 67 notes<br />

that any entity with risks arising<br />

from financial instruments that are<br />

“particularly significant” may need<br />

to provide additional disclosures<br />

to enable users to evaluate the<br />

significance of financial instruments<br />

to its financial position and<br />

performance.<br />

FRED 67 also proposes to remove<br />

retirement benefit plans from the<br />

list of entities defined as financial<br />

institutions; retirement benefit<br />

plans will still provide the specific<br />

disclosures specified for them by FRS<br />

102 Section 34.<br />

To make FRS 102 clearer and easier<br />

to use, FRED 67 proposes to add a<br />

number of examples illustrating<br />

which types of financial instruments<br />

should be accounted for at amortised<br />

cost and which types at fair value.<br />

Conclusion<br />

Given the very wide variety of<br />

companies that use FRS 102, from<br />

the largest private companies to<br />

much smaller entities, it is not<br />

surprising that a mix of views was<br />

expressed by stakeholders on the<br />

future of FRS 102, from those who<br />

asked for a significant relaxation<br />

of its requirements to those who<br />

considered it should move more<br />

quickly to keep pace with changes<br />

in IFRS. The FRC considered<br />

that requests for amendment in<br />

some areas may reflect incorrect<br />

application of FRS 102, rather than<br />

a lack of clarity in FRS 102. It may<br />

provide additional informal guidance<br />

on such issues.<br />

In finalising the 140 pages of<br />

proposals in FRED 67, the FRC has<br />

had to consider very carefully which<br />

aspects of FRS 102 should be relaxed<br />

and which aspects should be retained<br />

or improved, while identifying the<br />

aspects of accounting that should<br />

now be introduced into FRS 102.<br />

In accordance with its usual<br />

practice, the FRC has invited<br />

comments on its proposals with<br />

those comments due by 30 June 2017.<br />

As many of the proposals represent<br />

an easing of FRS 102, it is important<br />

to note that they will not be effective<br />

until the final revised FRS 102 is<br />

issued. While many commentators<br />

can be expected to agree with the<br />

FRC’s proposals, others may not be as<br />

supportive. Now that we have seen<br />

how open the FRC is to considering<br />

the views expressed by stakeholders,<br />

if you have views one way or the<br />

other on the proposals of FRED 67 to<br />

change our GAAP, why not accept the<br />

FRC’s invitation to comment?<br />

FIONA HACKETT<br />

Fiona Hackett FCA is a Director with PwC and<br />

a member of the Accounting Committee of<br />

Chartered Accountants Ireland.<br />

TERRY O’ROURKE<br />

Terry O’Rourke FCA is a Consultant with<br />

PwC and chairs the Accounting Committee<br />

of Chartered Accountants Ireland.<br />

ACCOUNTANCY IRELAND<br />

APRIL 2017

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