Takeshi Imamura
Certified Public Accountant
6－210 Shinmatsudo, Matsudo Chiba Prefecture 270－0034, Japan
Phone +8－47－346－3631
E-mail：aatcdr@sunny.ocn.ne.jp
28 September 2009
International Accounting Standards Board
30 Cannon Street
London EC4M 6XH
United Kingdom
Comments on the Exposure Draft“Fair Value Measurement”
Dear Sir／Madam
Thanks for the opportunity to comment on the Exposure Draft “ Fair Value
Measurement（ED）”
．
General comment
The Board seems to disregard the fundamental issue of“to recognise fair value or not
to recognise.” This issue is excepted from the scope of related projects.
For example, determining whether to recognise‘day 1’gains must be within the scope
of revenue recognition project. Revenue recognition project, however, avoids this
problem.
Comprehensive and exhaustive discussion about recognition of fair value should be
necessary.
Comments on individual questions
Question 1
Definition of fair value
Is this definition appropriate？ Why or why not？ If not, what would be a better
definition and why？
Comment
The proposed definition is appropriate.
However the following definition would be more appropriate.
“ Fair value is the price for which an asset could be exchanged, or a liability
transferred, between knowledgeable, willing parties in an arm,s length transaction at
the measurement date.”
Basis for comment：
１．The word“exchange”would be
necessary to clarify that fair value contains
exchange price notion.
２．When an exit price is different from an entry price at initial recognition, the
definition of fair value as an exit price may cause‘day 1’gains or losses.
In this case alternative definition regards transaction price as fair value. So it
prevents‘day 1’gains or losses.
Question 8
The exposure draft proposes that：
（a）the fair value of a liability reflects non-performance risk.
（b）the fair value of a liability is not affected by a restriction on an entity ,s ability to
transfer the liability.
Are these proposals appropriate？ Why or why not？
Comment
Proposal（a）
：
The proposal is not appropriate.
Basis for comment：
The proposed definition of fair value contains exchange price notion（paragraph BC
16）. Therefore the perspective of a transferee should be considered to determine the
price. Non-performance risk of an entity is indifferent to a transferee, because he
considers how much would he have to reserve now for future payment of an liability.
In this case he must consider yield rate.
Proposal（b）
：
The proposal is appropriate.
Yours faithfully,
Takeshi Imamura