Shane Buggle I Deputy Chief Financial Officer25 November 2015Mr Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH United KingdomDear Mr Hoogervorst/Sill gm• IRe: ED/2015/3 ‘Conceptual Framework for Financial Reporting’ ED/2015/4 ‘Updating References to the Conceptual Framework’Australia and New Zealand Banking Group Limited (ANZ) is listed on the Australian Securities Exchange. Our operations are predominantly based in Australia, New Zealand and the Asia Pacific region. Our most recent annual results reported profits before tax of A$10.5 billion (US$7.2 billion) and total assets of A$889.9 billion (US$640.2 billion).We welcome the opportunity to comment on these exposure drafts and support the project to develop an updated Conceptual Framework for financial reporting. Overall we do not consider the proposed Conceptual Framework reflected in ED/2015/3 will enhance its usefulness to: • the IASB when it develops International Financial Reporting Standards (IFRSs); or • others seeking to understand and apply IFRSs.Given the importance of a high quality, robust Conceptual Framework, we encourage the IASB to take as much time as is necessary to further develop and redeliberate the proposals to ensure that the revised framework is capable of both guiding and expediting the standard setting process rather than a broad codification of existing requirements that may largely defer debate to standards-level deliberations.Additionally, notwithstanding recent difficulties encountered by the IASB and FASB in achieving full convergence on various joint projects, we continue to believe full convergence with the United States is essential if IFRSs are to truly bring efficiency to global capital markets by facilitating comparability amongst competitors. Accordingly, we strongly recommend that the IASB re-engage with the FASB with the objective of achieving a converged Conceptual Framework prior to finalisation of the proposals. In our view, a converged Conceptual Framework must be the foundation for future convergence efforts.The key areas where we suggest that further development of the proposals in the exposure drafts is required are: • Definition of a liability, including the description of a present obligation and the accompanying guidance and testing of the application of the proposed definition against a wide variety of present and potential obligations; • Completion of the IASB’s separate project on the distinction between liabilities and equity; • Development of a well-defined theoretical foundation for alternative measurement bases with a clear nexus to the objective of financial statements and users’ information needs; • Development of a clear theoretical foundation differentiating between profit or loss and other comprehensive income; • Consideration of the extent to which ‘business activities’ (or the ‘business model’) should form part of the conceptual basis for standard setting;Level 9, 833 Collins Street, Docklands, VIC 3008 Australia I Phone +61 3 8655 5277 I anz.com Australia and New Zealand Banking Group Limited ABN 11 005 357 522
