Propostas do CBAN para padrões internacionais de avaliação (IVS) do Conselho Internacional de Padrões de Avaliação (IVSC) para 2016, compiladas pelo professor Carlos Eduardo Cardoso e Rodrigo Amato, diretor do CBAN São Paulo.

1. Comments on the Exposure Draft of Amendments of IVS 2015
The comments contained herein are the contribution of ANEFAC – CBAN to the
IVSC Proposed Amendments to the International Valuation Standards as of
2015.
Except on the items detailed in the following comments, we support all the other
proposed amendments.
Changes to Arrangement of Standards
The proposed amendment to include the TIP as annex to the application
standards will require that each time a new TIP be issued the standard is altered.
In the current structure, TIPS may be issued separately several times a year and
an amendment of the standard would be necessary for each. We suggest
alternatively that TIPS are maintained separate from standards. Another reason
is that one TIP, as Discounted Cash Flow is applicable to more than one
Application Standard.
Changes to Definition
Discharge Value
The new definition proposed of “discharge value” trying to supply the inadequacy
of the use of “investment value” for liabilities creates a term that may be
misleading. We do not support the search for a word that is different from a term
intended to be used in another standard issued by IASB. We believe the term
“fulfilment value” would be more appropriate. Alternatively, we suggest the use of
“liability value” which describes appropriately the nature of the value of the liability
for the specific entity.
IVS Framework
Price Cost and Value
The exclusion of the term “most probable” from the definition of value seems
appropriate. Nevertheless, the simple exclusion implies that “value is the price”
and thus the appraiser would determine the effective price to be paid. We believe
it makes more sense to use the expression “most likely” instead. This expression

2. implies that the appraiser will not estipulate the effective price but will recommend
the value based in some kind of rationale not necessarily probability based and
thus would fit the principle of a generic statement, still reinforcing the need for a
justified rationale.
Fair value
We agree with the change of the name “fair value” to “equitable value” once the
concept is intuitive. We suggest to maintain the definition of “fair value” equal to
the definition in IFRS or at least to state in the definition of “equitable value” that
the IVS recognizes the definition of “fair value” given by IFRS as prevailing and
being enforceable.
IVS 250 Annex 250.01
G1
We regard this paragraph as not necessary once the content is generic and
applicable to all the annexes of standards.
G4
We suggest the use of the expression. “dealers, brokers and price services”
instead of only “brokers and pricing services”. In OTC markets, dealers may
supply reliable information for the valuation.
G5
We suggest the exclusion of paragraph G5 once definition of internal control is
applicable to all types of assets and not specifically to financial instruments.
G8
We suggest the replacement of the expression. “by an independent department
of the entity" by the expression "by an external agent” so the independent
valuation can be carried out by internal as well as external agents. This also
agrees with the text in G9.

3. G9
As a matter of coherence with “Revision of Market Risk Framework” in use for
Basel I.5 and III, we suggest the inclusion of the item "a protocol for the frequency
and methods for independent testing of market data sources and usage"
G13
We suggest the use of “dealer and/or brokers” instead of only brokers because
in OTC markets, dealers may supply reliable information.
G15
Replace the expression. “broker” by “dealer and/or broker”.
G15 second bullet
Reinclude the word “for” after “as they would” to correct the text.
G15 third bullet
To make the text more coherent with G16 we suggest replace the text by "There
is an inherent conflict of interest where the dealer is the counterpart to an
instrument. However, for an OTC transaction this should be considered as one
of the sources and there should be an appropriate consideration of the conflict in
the validation policy and how it would be addressed and disclosed."
G18
Replace "required asset" by "required instrument" to be consistent with G15.
G22
We suggest the addition of a bullet with the text “"where the blockage factor of
the source or the party is relevant enough to have influence on the given
price/quotation".
G24
We suggest the addition of two bullets with the texts:
o "the directadministrativecostrelatedtothe instrument"
o "the time cost of moneyof fundingforassetsandinvestingforliabilities"

4. We suggest the following wording for Collateral “The assets to which the holder
of an instrument has recourse in the event of default need to be considered as
need to be the practicality of such recourse and agility.". This is important for
covered bonds, which are a relevant market internationally.
We suggest, for Default Protection, the addition of the text “that party's
creditworthiness (see Counterparty risk)” at the end of the paragraph after the
last word.