Overall, we believe the revised exposure drafts go some way to building an acceptable replacement for UK GAAP. The removal of the three-tier framework and with it, the use of public accountability to determine the application of EU-adopted IFRS, are especially welcome. But we feel that FREDs 46 to 48 need changing on estimated credit losses, expected interest rate and financial instruments to make the any accounting output meaningful and effective.
Update - 23 May 2012
At the invitation of the Accounting Standards Board, we submitted additional comments on the board's proposals for the future of UK GAAP. We focused on impairment, disclosures and EIR. Click below to read our further submission: