On 21 April 2015, Insurance Europe published supplementary comments to its March 2015 letter (written jointly with the European Insurance CFO Forum and submitted to the European Financial Reporting Advisory Group), which raised concerns regarding implementation of IFRS 9 and IFRS 4 Phase II.  The supplementary comments focus mainly on the negative effects of IFRS 9 being implemented ahead of IFRS 4 Phase II. Key concerns highlighted include that this will lead to (a) accounting mismatches in insurers' income statements and (b) significant costs and other operational impacts.