EFRAG welcomes the IASB proposals. EFRAG assesses that the temporary exemption from applying IFRS 9 is addressing all the concerns relating to the misalignment of IFRS 9 and the new insurance contracts Standard, in contrast to the overlay approach which is addressing only the accounting mismatches. However, EFRAG has been made aware that the overlay approach is a suitable approach for some banks which carry insurance activities. As a result, EFRAG supports both approaches as being complementary.


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