Our Ref.: C/FRSCSent through electronic mail3 January 2018Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IFRS 17 Insurance ContractsThe Hong Kong Institute of Certified Public Accountants ("HKICPA") is the only bodyauthorised by law to set and promulgate standards relating to financial reporting, auditing,and ethics for professional accountants, in Hong Kong.In accordance with our convergence policy, HKICPA has approved the issuance ofHKFRS 17 Insurance Contracts, a word-for-word adoption of IFRS 17 including transitionalprovisions and effective date. HKICPA's strong commitment to high quality globalstandards that are principle-based, understandable and implementable is unchanged.However, the adoption of HKFRS 17 has presented the HKICPA with circumstances thatwe wish to share with the IASB.Hong Kong's insurance regulator is developing its new regulatory capital requirements,expected to be rolled out in phases during 2021 to 2022. Hong Kong insurers will also berequired to provide detailed data for quantitative impact studies in the period leading up tothe effective date of HKFRS 17. Our insurance regulator is therefore concerned that thiswould put Hong Kong insurers, particularly the smaller insurers in the non-life insurancesector, under substantial strain, as they would be required to implement new financialreporting and regulatory capital requirements at the same time.Additionally, our insurance regulator has observed that smaller insurers in particular do nottypically have the in-house actuarial expertise required to cope with the significant changesin financial reporting requirements that HKFRS 17 introduces. Given the anticipated surgein demand for actuarial expertise from all insurers in the market, it would be difficult,particularly for these smaller insurers, to recruit experienced actuarial staff or engage well-qualified consultants to ensure implementation of HKFRS 17 by its effective date. HKICPAis aware that this shortage in actuarial expertise and other implementation resourcechallenges, such as the availability of IT solutions, is not unique to Hong Kong insurers,and is a concern shared across the Asia-Oceania region.HKICPA is aware of concerns among Hong Kong stakeholders about the possibility ofinconsistent adoption or application of IFRS 17 globally. As one of the leading globalfinancial centres, Hong Kong is home to many multinational insurance companies thatoperate a wide network of insurance businesses in Asia and other jurisdictions that applyIFRS Standards. The key concern from our stakeholders, in this regard, is that othernational or regional standard-setters or regulators may introduce guidance orpronouncements that would give more time to implement IFRS 17 or allow the applicationof its requirement in a way that is simpler than permitted under IFRS 17. This could createan unfair competitive disadvantage for entities reporting under HKFRS. HKICPA is alsoaware that these concerns are not unique to Hong Kong insurers.HKICPA considers that having a globally consistent standard, including effective date, isextremely important to Hong Kong as an international finance centre and is monitoring theprogress of implementation and any issues that may arise. However, should there be aneed in the future, HKICPA may consider whether it is necessary to deviate from IFRS 17,which we can do in some exceptional cases. HKICPA would also be supportive of theIASB modifying IFRS 17 if pervasive issues that prevent companies from complying withIFRS 17 were identified.In these circumstances, HKICPA encourages the IASB to continue its monitoring ofadoption and outreach activities, and proactively seek feedback from reporting entities asthey progress with their implementation projects. HKICPA would also be supportive of theIASB using the outcome of this outreach activity to promptly decide, where appropriate,amendments or simplifications to IFRS 17, especially if the requirements of the newstandard were operationally difficult to meet.Finally, HKICPA appreciates the ongoing support the IASB has offered to HKICPA and itsstakeholders in relation to IFRS 17, such as the investor and regulator education sessionsheld in Hong Kong in the second half of 2017. HKICPA urges the IASB to continue itseducation efforts with preparers, investors, regulators and governments around the worldto rally support behind IFRS 17. The IASB is also recommended to monitor the status ofavailable IT solutions, actuarial and other specialist resources for insurers globally as thiswill impact the companies' ability to practically implement IFRS 17 by 2021. Jurisdictionsand companies that are implementing IFRS 17 would, to some extent, be reassured by thislevel of IASB support.HKICPA supports the establishment of IASB's IFRS 17 Transition Resource Group andappreciates the appointment of Hong Kong-based insurance representatives as membersof this Group. HKICPA is setting up a HKFRS 17 implementation support group withsimilar objectives to the IASB's TRG. We will continue to assess implementationdevelopments in Hong Kong, share with the IASB's TRG the challenges with implementingHKFRS 17 and work together with the IASB in resolving those challenges.If you have any questions regarding the matters raised in this letter, please contact me(christinang@hkicpa.org.hk), or Kam Leung (kamleung@hkicpa.org.hk), Associate Directorof our Standard Setting Department.Yours sincerely,Christina NgDirector, Standard Setting Department
Letter to IASB: HKFRS 17 Insurance Contracts
下载原件Our Ref.: C/FRSCSent through electronic mail3 January 2018Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IFRS 17 Insurance ContractsThe Hong Kong Institute of Certified Public Accountants ("HKICPA") is the only bodyauthorised by law to set and promulgate standards relating to financial reporting, auditing,and ethics for professional accountants, in Hong Kong.In accordance with our convergence policy, HKICPA has approved the issuance ofHKFRS 17 Insurance Contracts, a word-for-word adoption of IFRS 17 including transitionalprovisions and effective date. HKICPA's strong commitment to high quality globalstandards that are principle-based, understandable and implementable is unchanged.However, the adoption of HKFRS 17 has presented the HKICPA with circumstances thatwe wish to share with the IASB.Hong Kong's insurance regulator is developing its new regulatory capital requirements,expected to be rolled out in phases during 2021 to 2022. Hong Kong insurers will also berequired to provide detailed data for quantitative impact studies in the period leading up tothe effective date of HKFRS 17. Our insurance regulator is therefore concerned that thiswould put Hong Kong insurers, particularly the smaller insurers in the non-life insurancesector, under substantial strain, as they would be required to implement new financialreporting and regulatory capital requirements at the same time.Additionally, our insurance regulator has observed that smaller insurers in particular do nottypically have the in-house actuarial expertise required to cope with the significant changesin financial reporting requirements that HKFRS 17 introduces. Given the anticipated surgein demand for actuarial expertise from all insurers in the market, it would be difficult,particularly for these smaller insurers, to recruit experienced actuarial staff or engage well-qualified consultants to ensure implementation of HKFRS 17 by its effective date. HKICPAis aware that this shortage in actuarial expertise and other implementation resourcechallenges, such as the availability of IT solutions, is not unique to Hong Kong insurers,and is a concern shared across the Asia-Oceania region.HKICPA is aware of concerns among Hong Kong stakeholders about the possibility ofinconsistent adoption or application of IFRS 17 globally. As one of the leading globalfinancial centres, Hong Kong is home to many multinational insurance companies thatoperate a wide network of insurance businesses in Asia and other jurisdictions that applyIFRS Standards. The key concern from our stakeholders, in this regard, is that othernational or regional standard-setters or regulators may introduce guidance orpronouncements that would give more time to implement IFRS 17 or allow the applicationof its requirement in a way that is simpler than permitted under IFRS 17. This could createan unfair competitive disadvantage for entities reporting under HKFRS. HKICPA is alsoaware that these concerns are not unique to Hong Kong insurers.HKICPA considers that having a globally consistent standard, including effective date, isextremely important to Hong Kong as an international finance centre and is monitoring theprogress of implementation and any issues that may arise. However, should there be aneed in the future, HKICPA may consider whether it is necessary to deviate from IFRS 17,which we can do in some exceptional cases. HKICPA would also be supportive of theIASB modifying IFRS 17 if pervasive issues that prevent companies from complying withIFRS 17 were identified.In these circumstances, HKICPA encourages the IASB to continue its monitoring ofadoption and outreach activities, and proactively seek feedback from reporting entities asthey progress with their implementation projects. HKICPA would also be supportive of theIASB using the outcome of this outreach activity to promptly decide, where appropriate,amendments or simplifications to IFRS 17, especially if the requirements of the newstandard were operationally difficult to meet.Finally, HKICPA appreciates the ongoing support the IASB has offered to HKICPA and itsstakeholders in relation to IFRS 17, such as the investor and regulator education sessionsheld in Hong Kong in the second half of 2017. HKICPA urges the IASB to continue itseducation efforts with preparers, investors, regulators and governments around the worldto rally support behind IFRS 17. The IASB is also recommended to monitor the status ofavailable IT solutions, actuarial and other specialist resources for insurers globally as thiswill impact the companies' ability to practically implement IFRS 17 by 2021. Jurisdictionsand companies that are implementing IFRS 17 would, to some extent, be reassured by thislevel of IASB support.HKICPA supports the establishment of IASB's IFRS 17 Transition Resource Group andappreciates the appointment of Hong Kong-based insurance representatives as membersof this Group. HKICPA is setting up a HKFRS 17 implementation support group withsimilar objectives to the IASB's TRG. We will continue to assess implementationdevelopments in Hong Kong, share with the IASB's TRG the challenges with implementingHKFRS 17 and work together with the IASB in resolving those challenges.If you have any questions regarding the matters raised in this letter, please contact me(christinang@hkicpa.org.hk), or Kam Leung (kamleung@hkicpa.org.hk), Associate Directorof our Standard Setting Department.Yours sincerely,Christina NgDirector, Standard Setting Department