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ALLIANCE FO§ DEMOCRACY
bombLetter to the IMF relation to the
Headbombno-value-ECM - 05/12/16
bombLetter to the CDU Youth Union - 14/11/16 bombLetter to the IDW regarding
Headbombthe EFSF’s Financial
HeadbombStatements – 19/10/16
Headbomb+ Correspondence IDW -> MFD 15/11/16
Headbomband MFD -> IDW 16/11/16
bombLetter to the european Financial
HeadbombSupervision relation to the
Headbombno-value-ECM - 03/10/16
bomb14th Letter to the Parliament for Judicial
HeadbombReview of the Free-Trade
HeadbombAgreements - 27/05/2016
bombApplication to the Constitutional
HeadbombCourt for Judicial Review of the
HeadbombFree-Trade Agreements - 27/05/2016
bombBILD - Pillory of Shame - 21/12/15 bombCriminal charge of making a false
Headbomballegation against netzpolitik.org - 17/09/2015
Headbomb+ response of Public Prosecutor in
HeadbombBerlin - 20/05/2016
bombLetter to the Ifo President - 05/11/14 bombComplaint to the German
HeadbombPress Council - 21/11/13
bombLetter to the IMF - 17/10/13
Headbomb+ Supplementary letter 22/11/13
bombLetter to the EU Commission - 17/10/13 bombLetter to the Presidium of the ECB - 17/10/13 bombAgainst the dismissal of
HeadbombFederal President Wulff - 13/06/13
Headbomb+ Response from the Hannover
HeadbombPublic Prosecutor's Office 25/07/13
Headbomb+ Opinion of the Alliance for
HeadbombDemocracy 21/08/13
Headbomb+ Letter to Celle General State Prosecutor’s
HeadbombOffice 10/10/13
bombPetition for the independence of the
HeadbombJudiciary and State Prosecutor - 06/05/13
Headbomb+ response by the Petitions Committee of
Headbombthe German Bundestag - 08/06/16
bombPetition for the introduction of genuine, direct
Headbombdemocracy - 25/04/13
Headbomb+ reply of the Bundestag - 14/11/16
bombPetition against corruption - 25/03/2013 bombCriminal complaint re. Target 2 10/11/2012 bomb1st Constitutional Complaint - against the
HeadbombFederal Government - 21/03/12
bomb2nd Constitutional Complaint - ESM incl.
Headbombsupplement - 12/06/12
bomb3rd Constitutional Complaint - ESM incl.
Headbombsupplement - 18/09/12
bomb4th Constitutional Complaint - Federal
HeadbombGouvernment against the ECB (by CJEU)
Headbomb27/09/12
Headbomb+ response of Federal
HeadbombConstitutional Court - 06/06/16
bombPress reports 27/6/12 + 24/10/12 bombSpringer complaint 28/09/11 bombDelayed insolvency bombPetition to the German Parliament 31/05/11 bombPetition to the European Parliament 21/06/11 bomb1st Letter to Members of Parliament 23/06/11 bomb2nd Letter to Members of Parliament
Headbomb26/09/11
bomb3rd Letter to Members of Parliament 19/05/12 bomb4th Letter to Members of Parliament 23/05/12 bomb5th Letter to Members of Parliament 20/06/12 bomb6th Letter to Members of Parliament 27/06/12 bomb7th Letter to the Parliament 27/9/12 bomb8th Letter to the Parliament 15/10/12 -
Headbombagainst Corruption 15/10/12 in addition to
HeadbombPetition 25/03/13
bomb9th Letter to the Parliament 24/10/12 bomb10th Letter to the Parliament 05/12/12 bomb11th Letter to the Parliament - 20/05/13 bomb12th Letter to the Parliament - 16/10/13 bomb13th Letter to the Parliament - 10/12/15 bombQuestions to the Bundestag 27/28/06/12 bombTo the members of the Bundesrat 14/06/12 bombTo the minister of finance 12/06/12 bombSecond Letter to the Finance
HeadbombMinister - 27/02/15
bombObjection to Hartz IV - Judicial Review
HeadbombComplaint BVerfG
bomb1st Lawsuit against Federal government
bomb21/03/11
bomb2nd Lawsuit against Federal government
bomb05/10/11
bombOpen letter 16/18/02/11





HeadbombLetter to the Institute of Auditors
Headbomb(IDW) regarding the EFSF’s
HeadbombFinancial Statements

Like the ESM, the EFSF is a Societé Anonyme (SA) under Luxembourg law, i.e. a public stock company. It can be readily assumed that public stock companies (in all European countries) are subject to financial reporting obligations.
In 2010, Luxembourg opened its accounting law to international financial reporting standards. Companies may now choose between Luxembourg accounting laws or international accounting standards for their final statements. Companies whose securities are traded on a regulatory market in the EU, such as the EFSF, must proceed according to international accounting standards. In its Annual Report 2015, the EFSF makes several references to the International Accounting Standards (IAS). The EFSF’s accounts were certified by PricewaterhouseCoopers. The Financial Report for 2015 reflects a loan receivable of €134.8 billion. This is the nominal amount. There was no value adjustment. The relevant IAS 39 provides for a "mixed model." The valuation can be based on either 1) the amortised cost or 2) the fair value. Obviously, the EFSF and PricewaterhouseCoopers used the amortised cost.
Pursuant to IAS 39.58, there must be value adjustment if there are objective indications of an impairment on the balance sheet date, but this was rejected in the 2015 Annual Report (see p. 40).
Under IAS 39.60, the downgrading of the credit rating alone is not sufficient to justify a value adjustment, but it can be regarded as one indicator among others. The ratings are shown on page 32 of the 2015 Financial Report:

Moody's Caa3 In default with little prospect for recovery
Standard & Poor's CCC+ Substantial risks
Fitch CCC Substantial risks

In In the tabular overview of the Financial Report, there is no direct reference to Greece. The claims against states are divided into three amounts. One of the amounts, €134.8 billion, receives a poor rating and is the amount that corresponds to the Greek liabilities. The rating could therefore be considered an indicator for a value adjustment. The decisive circumstances would seem to be the possible concessions of the creditors, and the general financial conditions of the debt haircut with private creditors in case of sovereign default, etc.
In the case of the EFSF claims, there was no debt relief, as with the private creditors, but even the EFSF had to pare some losses. The guarantee fee for Greece was omitted, meaning a loss of €2.7 billion for the EFSF. In addition, interest payments were deferred for 10 years, which means Greece pays no interest for 10 years. Finally, the loan maturity dates were postponed well into the future. It has until 2054 to pay off the loans. 
Greece’s total explicit debt burden is €319 billion, which is 182% of its GDP. Greece needs help, as always, and so a third aid package of €85 billion was set up in August 2015. Despite austerity measures, the debt burden is increasing. The unemployment rate is 25%. Economic growth is negative. In its mission concluding statement of 23 September 2016, the IMF describes the results of this desolate landscape for Greece: “Further debt relief will be required ... well beyond what is currently under consideration."
For the private creditors of Greece’s public debt, there has already been a debt haircut. At the Eurozone summit meeting on 21 July 2011, a €50 billion stake for the private sector in the bailout package was approved. In another resolution on 26 October 2011, support for Greece was expanded in the form of a 50% debt haircut.
In this context, the IDW identified an impairment trigger – i.e. the need for a value adjustment. Although the EFSF was not directly affected by this and was exempted from the haircut, the haircut in the private sector is an indicator for insolvency. The creditors are proportionately satisfied (with the insolvency).
Now that it is has been verified regarding whether the EFSF has earned the certification of PricewaterhouseCoopers and whether, and to what extent, this is appropriate, the Alliance for Democracy has written a letter to the Institute of Auditors (IDW).

In the meantime, we have received a reply – an unsatisfactory one, as it does not involve an independent audit of the balance sheet. But this is necessary, as the Alliance for Democracy has repeatedly insisted.
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