신흥개발경제에서 공개초안‘공정가치측정’의 적용이 어려운 경우에 관한 구체적인 사례 요청

2009. 12. 21

한국회계기준원

조사연구실

Ⅰ. 금번 IASB의 요청 목적

지난 2009년 5월 말 IASB는 공개초안 ‘공정가치측정’을 발표하고 외부검토의견을 수렴하였음

이 중 일부에서 신흥개발경제(emerging and transition econimies)의 기업의 경우 다음과 같은 이유로 실무상 공개초안의 원칙을 적용하기 어려울 수 있다는 의견이 제기됨

일관되게 공정가치를 측정할 수 있을 만큼 공개초안의 내용이 상세하지 않음

공개초안의 지침을 적용할 수 있는 실무자가 많지 않으며 기업들은 필요한 판단을 하는데 있어 익숙하지 않음

활성시장(active markets)이나 거래층이 두텁고 유동성이 높은 시장(deep markets)이 거의 없기 때문에 공정가치측정을 위한 시장자료의 접근이 제한되며 거래 의사가 있는 매수‧매도자가 없는 경우가 빈번하고 가격이 자주 심하게 변동함

공정가치측정 및 관련 공시를 준비하기 위해서는 많은 비용이 발생됨

이에 따라 IASB는 최종 ‘공정가치측정’ 기준서에 추가적인 명확화가 필요한 부분을 식별하기 위하여 신흥개발경제의 실무자에게 다음과 같이 요청하고 있음

요청사항:

‘ 공개초안에서 제안된 지침이 실무상 적용이 어려운 거래 혹은 상황에 대한 구체적인 사례’

이러한 사례를 검토한 후 ① 공개초안의 내용이 특정 상황에 적용하기에 불충분하다면 공개초안의 제안 내용을 수정하거나 ② 교육용 자료*를 발표, 혹은 이 둘 모두를 고려할 예정임

* 식별된 우려사항 및 발표될 기준서 ‘공정가치측정’과의 관계를 다룸

Ⅱ. 향후 일정

IASB는 2010년 1월 31일까지 관련 사례를 접수할 예정임

FASB와 Convergence를 위한 논의를 2010년 1월에 재개할 예정임

[별첨] Fair Value Measurement-Round Table에서 KASB가 제시한 의견*

* 회계법인의 Valuation 전문가분들과의 회의(2009.11.20) 결과를 근거로 함

[별첨] Fair Value Measurement-Round Table에서 KASB가 제시한 의견

Fair value in emerging and transition economies

The KASB supports the IASB's effort to precisely define the concept of fair value and to provide a single robust guidance on how to measure fair value of the items which is required or permitted by all the other standards. Also, we acknowledge that the exposure draft does not intend to introduce a new fair value concept and does not change the measurement objective in IFRSs.

Therefore, it may not be appropriate to mention the difficulties of the entities in emerging and transition economies applying the requirements of the exposure draft.

Nonetheless, as we believe the IFRS should be applicable not only to the entities in developed nations but also to the entities in emerging and transition economies, we would like to indicate some difficulties that could arise from the application of the exposure draft.

The main difficulties in applying the exposure drafts may be as follows.

1. Immaturity of transaction market

There is insufficient historical market data cumulated from past transactions because it has not been long since the market started to develop and it will take considerable periods for the market to become fully mature.

The fact that there are few deep and active markets make it difficult to obtain comparable data. And even when the comparable data is obtained, it is still challenging to adjust such comparable data or to assume hypothetical transaction considered from the perspective of market participants.

Moreover, the values measured by reporting entities in emerging economy are more likely to be categorized in Level 3 than in other Levels, which would damage reliability of the measurements on the financial statements.

2. Lack of specialist

Lack of valuation specialist with abundant experience in measuring fair value would raise the question about whether the requirements of exposure draft could be applied as appropriately as in the more developed markets. Also the reliability and objectivity of valuator could be questioned as well.

Auditors might find it burdensome to provide reasonable assurance on  the values measured by entities, because most of them have not been engaged in the audit on fair value measurement. In particular, in the case of valuation of non-financial items and derivatives, auditors would try to get relieved from potential litigation by basing their audit opinion solely on the estimation by external valuators or pricing companies who do not have proper accounting knowledge and are not under control of regulatory scheme, without independent assessment. As a result, the reliability of financial statements could be reduced.

3. Lack of measurement system

Apart from financial institutions, there are few companies having measurement system for the purpose of measuring fair value on their own.

Thus it would cost many companies enormous expense for constructing measurement system. In addition, although entities could establish measurement system, the constructed system could not operate efficiently because of the lack of practitioners and matured transaction market

As a result, we would like the IASB to consider publishing the additional guidance on how to fair value in the emerging and transition economies. For that purpose, we think that the IASB should understand, among others, the situation where the entities in the emerging and transition economies do not have enough experience on valuation as well as valuation experts and thus cannot provide comments on specific issues related to the exposure draft that may arise during their application.

We think that the IASB could find some solutions through meetings with knowledgeable valuation experts in developed financial markets. That is because those experts who have past experiences to invest in emerging and transition economies must have acquired practical knowledge on how to measure items in those markets. If such knowledge and experience are shared with the entities in emerging and transition economies, undoubtedly it will be very helpful to the entities in emerging and transition economies. As one of the methods to share their experience, we suggest that the IASB consider to include sufficient illustrative examples showing how to apply the exposure draft in emerging and transition economies

In addition, we would like to note that the IASB should deeply consider the best use of the educational guidance issued by Expert Advisory Panel in October 2008. This is because the educational guidance made by the technical experts specialized in valuing financial instruments can be more useful and helpful in practice than the principle-based standard. Therefore, we would like to suggest that the IASB include the contents of the report in the exposure draft more or clarify the status of the report