ISDA has responded to the International Accounting Standards Board’s IFRS 13 Post-implementation Review public consultation. Although our members are pleased with the principle-based approach used on the IFRS 13 standard to report fair value and the flexibility that it provides, our members are concerned with: (i) the costs associated with preparing the level 3 reconciliations; (ii) request to reconsider the use of P*Q for level 1 instruments, which assumes that the price that may be achieved for selling one share can also be achieved to sell a large holding; and (iii) recommends that any changes in this area should be coordinated with the Financial Accounting Standards Board.