We have published our comment letter on the International Accounting Standards Board’s Exposure Draft, ED/2013/3 ‘Financial Instruments: Expected Credit Losses’. We support the Board’s efforts to improve the accounting for recognition of credit losses on financial assets by addressing the weaknesses in the existing incurred loss model that were observed during the global financial crisis. We agree with the Board’s objective of recognising and measuring credit losses of financial assets on the basis of an entity’s current expectations about the collectability of contractual cash flows. However, we have a number of concerns about the proposed impairment model and suggest an alternate approach using an absolute assessment of credit quality which would avoid accounting anomalies when similar economics of financial assets are measured differently.