On January 12, 2022, ISDA submitted a response to the International Accounting Standards Board on the exposure draft related to International Financial Reporting Standard 13. ISDA’s members welcome the opportunity to review and improve the effectiveness of disclosures and reduce the burden on preparers. However, ISDA’s members do not believe that replacing the prescriptive disclosure requirements with overall disclosure objectives will lead to more decision-useful information. ISDA believes that the proposal could lead to practical challenges and a lack of comparability between entities and periods.