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Preparing for IFRS

accounting changes
Crucial developments for banks
April 2011
The frst three months of 2011 have seen the
International Accounting Standards Board
(IASB) propose profound changes to the
accounting for fnancial instruments. Moreover,
planned changes to many other standards will
likely impact the fnancial statements of banks.
1 Crucial developments for banks
The frst three months of 2011 have seen the International
Accounting Standards Board (IASB) propose profound changes
to the accounting for fnancial instruments. Moreover, planned
changes to many other standards will likely impact the fnancial
statements of banks.
The most signifcant change for the banking sector will be
the new fnancial instruments standard, IFRS 9. It will replace
the current IAS 39 Financial Instruments: Recognition and
Measurement and consist of three phases: classifcation and
measurement, impairment, and hedge accounting.
The impact of IFRS 9 for banks will be considerable. Almost the
entire asset side of the balance sheet will be affected, while the
processes for determining the loan loss provision for items at
amortized cost will be dramatically different. However, a greater
use of hedge accounting should be possible. It should also be
noted that the issues related to macro (portfolio) hedging will
only be addressed by the IASB when it publishes a separate
exposure draft (ED) in the second half of 2011.
In addition, in January 2011, the IASB and the US FASB (the
Boards) issued a joint ED, proposing new rules for offsetting to
address the differences in the offset requirements of US GAAP
and IFRS. These proposals are similar to the current offsetting
requirements of IAS 32 Financial Instruments: Presentation.
This exposure draft clarifes that the right to offset should be
unconditional and that settling ‘simultaneously’ means ‘at the
exact same moment’. Consequently, this could impact IFRS
reporters who execute contracts through clearing houses.
There are other signifcant proposals to change the accounting
standards that will have further consequences for banks. These
proposals, when fnalized, will revise the accounting for a number
of areas, including: leases; consolidation; revenue recognition;
fair value measurement; insurance contracts; and pensions.
Although the effective dates for all these changes are still
uncertain, given the far-reaching nature of the proposals, the
banking industry cannot afford to be complacent. Other than the
provisions for macro hedging, the IASB’s work plan
that the period to the end of 2011 is crucial, as all major
decisions are expected to be made by then. As these decisions
are made by the IASB, so too will the fnal impact on the banking
sector be determined. Entities in the European Union (EU) should
note that the EU has not yet started the endorsement process
for IFRS 9. The EU has suggested on several occasions that it
will only do so when the IASB has a fnal version of IFRS 9 that
includes macro hedging. Thus, EU entities will not be able to
early adopt the various phases of IFRS 9 as they are issued.
1 The IASB’s project work plan can be found on their website ( This is updated on a regular
basis by the IASB.
2 Preparing for IFRS accounting changes April 2011
The frst phase of IFRS 9, which has been fnalized, considers
the classifcation and measurement of both fnancial assets
and fnancial liabilities. IFRS 9 replaces the four measurement
categories for fnancial assets under IAS 39 with two categories:
fair value and amortized cost. The requirements for fnancial
liabilities remain largely unchanged; as before, these will be
classifed into fair value and amortized cost categories.
IFRS 9 allows fnancial assets that are non-derivative debt
instruments to be recorded at amortized cost, provided that they
meet two criteria. First, the entity employs a business model
to hold the assets, not sell them. Second, the characteristics of
the assets are such that the cash fows only represent principal
and interest. All other fnancial assets are recorded at fair value
through proft or loss, with only one permitted exception. This
exception relates to any non-trading equity investments that an
entity holds. For these non-trading equity investments, there is
a choice to record changes in fair value in Other Comprehensive
Income (OCI). In adopting this approach, the IASB has dropped
the IAS 39 requirement for fnancial assets to identify and
separate embedded derivatives that are not closely related to the
host fnancial assets.
One signifcant change has been made to the existing IAS
39 requirements for fnancial liabilities in order to address
the much-criticized issue of entities recording a proft when
their credit quality worsens. Where the fair value option has
been elected, IFRS 9 requires that changes in the fair value
of fnancial liabilities, which relate to the entity’s own credit
risk, are recorded in OCI rather than proft and loss. All other
requirements relating to the classifcation and measurement
of fnancial liabilities have been carried over from IAS 39. This
includes the separation of embedded derivatives in fnancial
liabilities. Therefore, most fnancial liabilities will continue to be
accounted for at amortized cost.
Even though the IASB and the Financial Accounting Standards
Board (FASB) have announced their intention to converge
standards, there are still signifcant differences between
phase 1 of IFRS 9 and the FASB proposals for accounting
for fnancial instruments. In its proposals, the FASB has
effectively retained an available for sale (AFS) category for
debt securities. The IASB plans to publish the FASB proposals
on their website, together with a request for comments on this
treatment for debt securities. It is currently unclear how this
will impact IFRS 9, if at all.
It should also be noted that the European Financial Reporting
Advisory Group (EFRAG), the technical advisory committee for
the EU, has suggested retaining the embedded derivatives rules
Phase 1: Classifcation and measurement
for fnancial assets, the available for sale classifcation, as well as
relaxing the business model test.
Compared with IAS 39, there is little doubt that IFRS 9 contains
fewer classifcation and measurement categories for fnancial
assets. The changes that IFRS 9 brings also eliminate the
complex, rule-based requirements for separating embedded
derivatives from fnancial assets, the tainting rules for held-
to-maturity investments and the diffculties in determining
impairment for AFS assets. Entities that hold impaired AFS debt
securities will no longer need to recognize the full fair value
decline in proft or loss, as they currently do upon impairment
of those assets under IAS 39, provided they meet the criteria
for amortized cost. For equity instruments recorded at fair
value through OCI, all declines in fair value will be recorded in
OCI. Although many items in the current AFS portfolio might
be measured at amortized cost under the new rules, other
instruments in the AFS portfolio will likely be recorded at fair
value (through proft or loss or OCI). Entities will need to apply
judgement in determining the appropriate classifcation.
The effects of applying the new standard will differ from one
entity to another. In order to determine the correct accounting
treatment under IFRS 9, companies will potentially need to
assess their different business models and segment their asset
portfolios accordingly.
In some cases, adopting the new standard prior to the mandatory
application date will be benefcial (where local endorsement
rules permit this), for example, when IFRS 9 is applied in
2011 comparative numbers do not need to be changed, but
banks need to assess the operational implications of the new
accounting requirements. As such, systems and processes need
to change signifcantly in order to calculate and record changes
in fair value along with adjustments to the fnancial instrument
disclosures required under IFRS 7. A concern for banks will also
be the impact on regulatory capital and taxation.
Ernst & Young publications
The following Ernst & Young publications contain details of the
new rules and can be downloaded at
Supplement to IFRS Outlook Issue 89 • IASB completes Phase
1 of IFRS 9: Financial Instruments — Classifcation and
Supplement to IFRS Outlook Issue 60 • IASB publishes IFRS 9:
Phase 1 of new standard to replace IAS 39
Implementing phase 1 of IFRS 9 •
3 Crucial developments for banks
In January 2011, the IASB published an important
supplementary document (SD) to the exposure draft (ED) that
was originally issued in November 2009, which proposed a
model based on expected losses arising from the impairment
of fnancial assets. In effect, this concept will require banks to
anticipate future losses, including the assessment of future
economic conditions.
The SD is a joint effort by the IASB and the FASB to seek a
more pragmatic approach to the issue of impairment based on
comments received on the initial ED. The SD provides guidance
on how to determine and account for impairment losses on loans
recorded at amortized cost that are managed in open portfolios.
The joint approach should be easier to apply to open portfolios
than the expected cash fows approach set out in the initial ED.
For example, the proposal now decouples the impairment losses
from the effective interest calculations.
Good book/bad book
The joint approach requires that fnancial assets are assessed for
impairment in portfolios of assets with similar characteristics.
Portfolios are divided into a ‘good book’, for which management
expects to receive regular payments from the assets, and a
‘bad book’, for which the objective is changed to recover all or a
portion of the assets.
The allowance recorded for the good book at any reporting date
would be the higher of: (i) the ‘time-proportional’ amount of the
total lifetime expected credit losses; and (ii) the amount of credit
losses expected to occur within the ‘foreseeable future period’ –
the ‘foor’. Consider, for example, for a fve year loan for which
losses of CU 2 are expected in the foreseeable future (say 12
months) and total losses of CU 6 are expected over the life of the
loan. In this case, a loan loss provision of CU 2 is recorded in the
period the loan is granted for the expected loss in the foreseeable
future. In the following years, assuming the expectations are
unchanged, CU 1 is added to the loan loss provision in each year.
The foreseeable future period is not specifcally defned in the
SD, but is proposed to be at least 12 months. Consequently,
entities with different views on the foreseeable future period
could arrive at signifcantly different loan loss allowances.
Recording a loss
The foor requirement will usually result in entities recording
a loss in the period that a loan is granted. For portfolios of
shorter term assets this loss could represent the entire lifetime
expected loss.
When the collectability of an individual asset (or a group of
assets) becomes so uncertain that the entity’s credit risk
management objective changes from that of receiving regular
payments to recovery of all or a portion of the fnancial asset,
it is separated from the portfolio of assets in the good book
and transferred to the bad book. The lifetime expected losses
on all assets transferred to the bad book are fully provided for
immediately on transfer.
The IASB and FASB’s SD does not mandate a specifc approach
for estimating lifetime expected losses. In practice, entities
may develop projections for expected losses on the basis of
specifc inputs, such as forecast information, for shorter-term
periods, and they may use long-term average loss rates based
on historical data for more distant periods. Under the proposals,
estimates of lifetime expected losses could vary signifcantly,
depending on how the bad book is defned and what is deemed to
be the foreseeable future period.
The impairment of short-term receivables and debt securities is
not addressed in the SD.
The proposed changes to impairment standards are far-reaching
as they apply to every loan reported at amortized cost, and not
just to loans with incurred losses as under the current IAS 39.
Judgement will need to be exercised in assessing and updating
expected future credit losses. The comparability of reported
fgures between different entities will also be affected by the
subjective nature of the judgements made in determining the
foor and defning the bad book.
Estimating the amount and timing of cash fows over the entire
lives of all fnancial assets at amortized cost will also require
signifcant new processes and controls to be introduced. This
will create changes to both key performance indicators and
procedures for impairment assessment. Even though the
proposals decouple the impairment losses from the effective
interest calculations for open portfolios, systems will still have
to be assessed and modifed in order to be able to provide the
relevant information in a more effective manner.
Ernst & Young publications
The following Ernst & Young publication contains details of the
proposals and can be downloaded at
Supplement to IFRS Outlook Issue 95 • IASB and US FASB
propose a joint approach to accounting for credit losses
Phase 2: Impairment
4 Preparing for IFRS accounting changes April 2011
In an effort to substantially simplify hedge accounting, the
IASB issued an ED in December 2010. The ED only sets out the
basic hedge accounting model, but it does not address macro
hedging. The most signifcant proposed change is that the
‘bright line’ test of 80-125% for hedge effectiveness testing will
be eliminated, though ineffectiveness is still to be measured
and included in proft or loss when it occurs. Under IAS 39,
banks may have to frequently de-designate and re-designate
hedge relationships, for example, because of a reduction in
the expected ‘highly probable’ cash fows, or a change in the
basis between hedging instrument and hedged item such that
the hedge is no longer ‘highly effective’. The proposals in the
ED will make it possible to rebalance the hedge relationship
without such discontinuation, provided that there is no change
to the risk management objective.
Hedging of risk components will be permitted for both fnancial
and non-fnancial items, if these are separately identifable and
measurable. Furthermore, voluntary de-designation will not be
permitted if the risk management objective continues to be met.
However, it will not be possible to apply hedge accounting to
equity instruments recorded at fair value through OCI. Signifcant
new disclosure requirements will also be required from preparers
of fnancial statements.
The simplifcation of the current hedge accounting
requirements is welcome. The current IAS 39 hedge accounting
requirements create a number of challenges for banks with
respect to designation, documentation, measurement and
effectiveness testing. Therefore, banks should start to consider
what further hedge accounting opportunities exist under the
proposals (e.g., using options), where these are less attractive
or not possible under the current IAS 39. Moreover, the
relaxation of the hedge accounting rules might result in greater
demand for derivatives. Bank customers, for example, will be
able to hedge components of non-fnancial risks and apply
hedge accounting under the new rules.
Phase 3: Hedge accounting
Macro hedging
Macro hedging, or portfolio hedging for interest rate risk, was not
included in the ED for hedge accounting. The IASB has only now
commenced its discussions on a macro hedge accounting model
for open portfolios.
The EU created a ‘carve-out’ in 2005 from certain aspects of
the IAS 39 hedge accounting rules to ease hedge accounting.
These aspects included: hedges of prepayment risk in macro fair
value hedges; hedges where the hedged risk is lower than that
represented in the hedge instrument (also known as the sub-libor
issue); and also to enable fair value hedge accounting on demand
deposits. It is expected that the IASB will attempt to address
these issues when discussing macro hedge accounting. However,
it is not yet clear whether the new proposals will have the same
broad effect as the EU carve-out had.
The impact of any change to the current macro hedge rules
would be signifcant. Most banks apply the macro hedge either
in a fair value alternative or a cash fow alternative. Several
European banks apply the carve-out to resolve the prepayment
and/or sub-libor issue. These models are usually implemented
through the substantial use of bespoke software solutions that
will need to be modifed.
Ernst & Young publications
The following Ernst & Young publications which contain details of
the proposals can be downloaded at
Supplement to IFRS Outlook Issue 91 • Hedge accounting under
IFRS — all set for change
Hedge accounting under IFRS 9 • — a closer look at the changes
and challenges
5 Crucial developments for banks
The proposals presented in the ED are similar to the offsetting
requirements in IAS 32, but there are certain important differences.
The IASB and FASB have proposed that an entity should offset a
recognized fnancial asset and a recognized fnancial liability, and
present the net amount in the balance sheet, when (and only when)
the entity:
Has an unconditional and legally enforceable right to set off the •
fnancial asset and fnancial liability, and;
Intends either to settle the fnancial asset and fnancial liability on •
a net basis, or to realize the fnancial asset and settle the fnancial
liability simultaneously.
In all other circumstances, fnancial assets and fnancial liabilities are
presented separately from each other according to their nature as
assets or liabilities.
Even though these requirements are very similar to the current IAS
32, the proposed rules appear to be stricter in certain circumstances.
They clarify that the legal right to offset should exist under all
circumstances (including bankruptcy of the counterparty) and that
‘simultaneously’ means ‘at the exact same moment’. The latter
requirement is likely to create a signifcant change for IFRS reporters
who currently apply netting to contracts with the same counterparty
which settle on the same day through a clearing house that processes
transactions in batches rather than at the exact same moment.
Ernst & Young publications
See our Supplement to IFRS Outlook Issue 94 for details of the
proposals, this can be downloaded at
6 Preparing for IFRS accounting changes April 2011
Timing of all the changes
A key concern for banks is the effective dates for applying the
new standards. In October 2010, both the IASB and FASB issued
a consultation document seeking views about the time and
effort that would be involved in implementing the proposed new
standards, including IFRS 9. The IASB is currently considering
the responses. At present, it remains unclear what the effective
date will be for these standards. It would appear that a majority
of IASB respondents favoured a single date no earlier than 1
January 2015, provided that the fnal standards are issued in
2011. This would include the effective date for IFRS 9.
Irrespective of the date that is eventually agreed upon by the
IASB for implementing IFRS 9, banks will need substantial time
to assess the impact on systems and processes and to implement
new solutions. Estimates suggest that a six-month assessment
period and a 30-month implementation timeline, or possibly
more, would not be unusual. Furthermore, initial estimates
show that the implementation could cost almost as much as the
conversion from local GAAP to IFRS in 2005. It is worth stressing
that if the mandatory date for the adoption of IFRS 9 remains
unchanged at 1 January 2013, then the earliest comparative
period has already begun for SEC registrants who must present
comparative information for two years.
Other signifcant changes in IFRS impacting banks
In addition to the replacement of the current IFRS guidance
for fnancial instruments, there are several other signifcant
accounting changes that banks will need to address.
Other relevant changes to IFRS expected to be fnalized in 2011
by the IASB are:
Group entities: • A consolidation standard is anticipated to be
issued in April 2011. This standard will state that consolidated
fnancial statements include all controlled entities using a
single control model. This is a change from the current two-
model approach that exists under IAS 27 and SIC-12. Banks
will need to reassess which entities, especially structured
entities, it controls under the new standard. Furthermore,
banking clients that create structured entities in order to
implement specifc products offered by banks may be affected
by these changes. The changes would not only result in
reassessments of consolidation when the new standard is
implemented, but continuous re-assessment would also be
required as facts and circumstances change. This standard will
be accompanied by a new standard on joint arrangements.
Leases: • The IASB has outlined a single model (the ‘right-of-
use’ model) for leases instead of using two separate models
for operating and fnance leases. This new approach would
result in all leases being included in the statement of fnancial
position of lessees. Potentially, this could have a signifcant
impact for the leasing business of banks. The potential impact
on solvency ratios of lessees could result in other forms of
fnancing being more attractive.
Revenue recognition: • The IASB proposes a single revenue
recognition model for all revenue transactions arising from
contracts with customers, (i.e., contracts for goods, services,
licences or fees). This will impact the revenue recognition of
various fees earned by entities in the fnancial sector, where
these fees are not within the scope of IAS 39 and/or IFRS
9. The IASB is currently re-deliberating certain aspects of
this model, including how revenue should be recognized for
Fair values: • The IASB will publish a separate standard on
fair value measurement. This will clarify the defnition of
fair value and establish a single source of guidance for all fair
value measurements required or permitted by different IFRS
standards. The IASB’s objective is to reduce complexity and
improve consistency in the application of IFRS. The proposals
could affect the way banks determine fair value of fnancial
instruments and other items. The proposals will result in
additional disclosures in the notes to the fnancial statements.
Insurance contracts: • The current standard for insurance
contracts, IFRS 4, contains very little recognition and
measurement guidance. The IASB has proposed one
comprehensive measurement approach for all types of
insurance contracts issued by entities (and reinsurance
contracts held by entities), with a modifed approach for
some short-duration contracts. Insurance liabilities would be
recorded at the present value of the fulflment value cash
fows. This is closer to fair value and is made up of an unbiased
probability-weighted average of the future cash fows expected
to arise as the insurer fulfls the obligation to its policyholders.
In addition to the above elements, the proposed model,
through a residual margin, recognizes proftability over the life
of the contract. For banks that sell insurance contracts, it is
likely that the proposals will signifcantly affect the accounting
for those contracts.
Financial guarantee contracts and loan commitments: • The
IASB had originally proposed to bring fnancial guarantee
contracts within the scope of the insurance standard. As
many banks issue fnancial guarantee contracts the current
proposals relating to insurance contracts are not only relevant
for insurance companies but also to these banks. However,
the Board is now exploring whether these contracts could
7 Crucial developments for banks
be accounted for under the new impairment model for
fnancial assets. Finally, the IASB is considering whether
loan commitments should also be accounted for under the
impairment model.
Employee benefts: • The IASB has proposed to remove both
the corridor approach from IAS 19 for defned beneft pension
plans, and the option for entities to recognize all changes in
defned beneft obligations and the fair value of plan assets
in proft or loss. Although the processes for obtaining the
information might not be substantially different from that
which is required under current rules, the fnancial impact
on proft will be substantial if all actuarial differences and fair
value movements are recorded in OCI.
What is the business impact?
The IFRS changes will impact the business, systems and
processes, as well as the investor communications, of banks.
Entities will need to evaluate these implications and plan their
responses. In addition, entities should consider the timing of
the adoption of any new standards. The benefts provided by
the transitional relief, such as the requirement not to restate
comparatives if applied in 2011, could prove benefcial.
In parallel with assessing the impact of the IFRS changes, entities
will need to consider the interaction between the accounting
changes and wider regulatory and macro-economic challenges.
These include:
Basel III •
Markets in Financial Instruments Directive •
Dodd-Frank Act •
Foreign Account Tax Compliance Act (FATCA) •
Jurisdictional banking levies and taxes •
Examples of some of the commercial, fnancial, regulatory and
organizational challenges that exist for banks are:
How to manage expectations and educate external •
stakeholders during the period of change
Understanding the decisions made by their industry peers •
Product restructuring where current products and business •
models may no longer be viable for a bank or its counterparty
How reclassifcations will impact key ratios, regulatory capital •
and tax
What improved systems capability and data will be required to •
meet the more onerous disclosure requirements
Assessment of the increased operational risk caused by •
changes to systems and processes
Organization-wide change management: increased •
competition for resources, systems, data and process
alignment, and management of quality and cost
In order to make an informed assessment, entities will need to
understand what are the signifcant accounting and operational
business impacts. Some of the new or proposed standards, in
particular, those relating to the classifcation, measurement and
impairment of fnancial instruments, are less rules-based and,
hence, management will be required to exercise considerable
judgement in implementing the changes to IFRS.
8 Preparing for IFRS accounting changes April 2011
Ernst & Young can bring its multi-disciplinary team of accounting, tax, systems, and IT professionals to your company to assist in
assessing what the accounting changes mean to you. In the chart below, we outline issues and steps the company should consider
related to accounting changes, and indicate how Ernst & Young may be able to help you from initial assessment through to adoption.
How can Ernst & Young help?
Issues and steps How Ernst & Young can help
Gain a general understanding of the new or
proposed accounting standards
  Design and deliver a training session for company personnel on the accounting implications of •
the new or proposed standards
  Share insights of IASB views, including interpretations •
Perform a preliminary assessment of the
impact of the proposal on the company’s
fnancial statements and regulatory capital
Advise and provide input into:
  Gathering necessary scoping information to implement the new or proposed standards •
  Calculating the income statement impact of implementing the new or proposed standards •
  Assessing impact on key fnancial ratios and performance measures •
  Identifying shortfalls in available information to implement the new or proposed standards •
  Assessing impact on regulatory capital •
  For a non-audit client, Ernst & Young can provide support, through the use of an automated •
tool, to determine the characteristics of fnancial assets for IFRS 9 classifcation. This tool is
able to run queries through large data sets and identify features to help determine fair value
classifcation using information from external data vendors. The use of this tool can reduce
the time needed to analyze instruments that would require fair value classifcation based
on characteristics of the instrument. This automated approach is also available for use on
contractually linked instruments. For audit clients, Ernst & Young can use the tool to evaluate
assessments made independently by company management.
Benchmark the company against peers and
others in the industry
  Provide observations of how others are approaching the new or proposed standards, •
problems they are identifying and solutions developed
  Assist in the evaluation of peers, competitors and industry disclosures and expected impact •
on the fnancial statements
Assess processes for data collection, internal
controls, IT systems
  Provide observations and insights based on leading practices regarding ways the company •
could design its business processes, IT systems, and internal controls to capture information
necessary to apply new or proposed standards
  Provide criteria to consider in selecting IT packages, and assist in the selection process •
Assess tax positions relating to the new or
proposed accounting standards
  Assist in analyzing tax positions arising from adopting the new or proposed standards, •
reducing tax exposure, and determining tax effects of any accounting changes
Plan for ultimate implementation of the new or
proposed standards
  Advise on the implementation of the new or proposed standards using an established •
  Advice regarding your project maintenance and planning, including timeline, tasks, and •
resource allocation
Advise management during the implementation   Advise management where the new or proposed standards require careful use of judgment •
  Review and provide input into accounting manuals and policies selected by management •
  Provide coordinated support to you of the Ernst & Young subject matter resources •
(Regulatory, Tax, Finance Transformation, etc.) on a global basis
Communicate effect of implementation
to stakeholders − analysts, regulators,
  Advise on developing a communication plan •
  Advise on drafting communications •
EMEIA Financial Services FAAS Leader
Tara Kengla
+44 20 7951 3054
Country leaders
Sylvie Goethals
+32 2 774 9518
Jean-Francois Hubin
+32 2 774 92 66
Channel Islands
Chris Matthews
+44 1534 288 610
Amaury de La Bouillerie
+33 1 46 93 65 80
Laure Guegan
+33 1 46 93 63 58
Edgar Loew
+49 6196 996 29011
Vincent Bergin
+353 1 2212 516
Wassim Abou Said
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Ambrogio Virgilio
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Peter Laan
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Manuel Martinez Pedraza
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Stefan Schmid
+41 58 286 3416
John Alton
+41 58 286 4269
United Kingdom
Sarah Williams
+44 20 7951 1703
Tony Clifford
+44 20 7951 2250

EMEIA Financial Services IFRS Leader
Michiel van der Lof
+31 88 40 71030

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