IIF response to IASB ED on prepayment features with negative compensation

In the letter, we put forth that we support the IASB's initiative to make a targeted and focused amendment to IFRS 9. The amendments should address the late-breaking issue about financial instruments with prepayment features and make sure their classification and measurement provide useful information to financial statements' users.

That is all the more salient that in some jurisdictions loans with symmetric prepayment options are a common market practice. There is no doubt that given the basic features of such loans, amortized cost continues to provide useful information, as was the case under IAS 39. Such measurement better represents than fair value the economic substance of the relevant business models for such basic lending arrangements.

Hereby, we stress that the timeliness and scope of the amendment are key. Indeed, it is crucial that the amendments are applied with the same effective date as IFRS 9 as a whole. But the amendments should equally be limited to what is necessary to clear up the raised issue.

Finally, it should not be necessary to include additional explanatory text as it may de-facto create additional requirements which are not in the standard itself or may create uncertainty with regard to other aspects of the "˜solely payments of principal and interest' (SPPI) notion.