Analysis of the comment letters on
The IASB invited those with an interest in its work to comment in writing on the improvements being implemented or proposed. The deadline for comments was 25 June 2004.
The Board received 50 submissions commenting on its paper. In general the comment letters support the proposed changes to the deliberative process. Respondents also suggested additional steps for the IASB's due process.
The Board indicated that its intention as a result of this process was to publish a manual similar to the FASB Rules of Procedure that sets out the principles that underlie the deliberative process without setting detailed procedures.
The Board discussed the following:
- There seemed to be some misunderstanding amongst respondents about the differences between field tests and field visits as evidenced by certain comments received. The Board clarified that field tests would be undertaken on a selective basis at the discretion of the IASB.
- Staff noted that on the whole, the suggestions made by the IASB were generally viewed as adequate, but there remained a need for the Board to communicate better and more visibly, the processes that it undertakes in developing Standards.
- The Board disagreed with requests for it to perform an impact analysis for each major project. The scope for such analysis would be too wide. The Board underscored its role, which is to set high quality accounting Standards and that this should not be confused with the perception that the IASB is responsible for directing capital markets. The Board will consider adding this to the conceptual framework.
- Although updates to the Trustees are currently presented by the Chairman of the Board, Staff suggested that this be more formalised in future.
- The Board noted that in the recent past, comment periods to exposure drafts have been relatively short, primarily due to the 2005 deadline. The Board agreed to extend the time frames given to constituents in future.
- Publishing of near final exposure drafts was seen as not serving any particular interest. Instead, the Board will only publish near final drafts as this is viewed as more useful to constituents. Project summaries will continue to be made available on the IASB website.