ISDA’s Accounting Committee has responded to the International Accounting Standards Board’s discussion paper, Financial Instruments with Characteristics of Equity DP/2018/1. ISDA’s members accept that IAS 32 Financial Instruments: Disclosure and Presentation includes a number of accounting requirements that can be improved. However, we don’t believe the standard is ‘broken’ and in need of a totally new model with untested principles that may have unintended consequences. Therefore, our members believe there are parts of the analysis carried out in the discussion paper that could be used to improve IAS 32 and resolve some of the long-standing issues, rather than require entirely new and untested accounting rules.