May

Deloitte letter on ED 8 on segment reporting

13 May 2006

We have posted the Deloitte letter of comments to the IASB on (PDF 45k).

Our overall view:

Whilst we support much of the Board's strategy on convergence between IFRS and US GAAP, we do not believe that the tactic on converging the requirements on segmental reporting is necessary at this time, and share many of the concerns of the three dissenting Board members. We believe that convergence should be to the superior standard and, as discussed further below, do not believe that a sufficient case has been made that moving to the approach required by SFAS 131 Disclosures about Segments of an Enterprise and Related Information would result in enhanced segmental disclosures.

In 1997, when IAS 14 and SFAS 131 were being developed, the IASC deliberately chose not to take a purely management approach to segmental reporting. We do not believe that convergence alone is justification for the proposed changes. Segmental reporting is solely a disclosure requirement and so does not affect reconciliations between IFRS and US GAAP. The convergence project should focus on items reported in the primary financial statements. If the two Boards believe that IAS 14 needs improving, they should do so by considering the advantages and disadvantages of both it and SFAS 131, rather than converge to a single standard that has not proved to be superior and we believe to be inferior.

IASB May 2006 meeting agenda

12 May 2006

The International Accounting Standards Board will hold its May 2006 Board meeting at its offices in London on Tuesday through Friday 23-26 May 2006. Presented below is the preliminary agenda for the meeting. 23-26 May 2006, London Tuesday 23 May 2006 (afternoon only) Service Concession Arrangements [Education Session] - to update the Board on IFRIC's deliberations Wednesday 24 May 2006 Insurance Contracts - Phase 2 Universal life contracts, unit-linked and index-linked payments and credit characteristics of insurance Reinsurance Salvage rights and subrogation rights Insurance contracts acquired in business combinations or portfolio transfers Changes in insurance liabilities Overview of FASB projects on risk transfer, life settlements, and financial guarantees Participation features Long-term savings contracts Pensions Agenda Proposal: Related Party Disclosures - proposal to amend IAS 24 for: Exclusion of state-owned entities from disclosing related party transactions with other state owned entities. Transactions between associates and subsidiaries of the same entity IFRIC Update Thursday 25 May 2006 Accounting Standards for Small and Medium-sized Entities - review of a revised draft ED Fair Value Measurement - FASB draft Standard Business Combinations II Amendment to IFRS 1: Cost of a subsidiary in the separate financial statements of a parent on first-time adoption.

Proposed amendment would provide relief from the requirement to restate cost in accordance with IAS 27 on first time adoption. Friday 26 May 2006 (morning only)

Notes from day 1 of the IFRIC meeting

12 May 2006

The International Financial Reporting Interpretations Committee (IFRIC) is meeting at the IASB's offices in London on Thursday 11 May and Friday 12 May 2006. Presented below are the preliminary and unofficial notes taken by Deloitte observers at the first day of the meeting.Notes from the IFRIC Meeting11 May 2006 IAS 17 Leases – Recognition of contingent rentals The IFRIC considered a request from a constituent for clarification of IAS 17's requirements on contingent rentals.

The issue arises from an alleged conflict between the definition of contingent rent in IAS 17 paragraph 4 and the requirements in IAS 17 paragraphs 33 (lessee accounting) and 50 (lessor accounting). The issue is whether contingent rentals (as defined) are included in the estimate of total lease payments/income to be recognised on a straight-line basis over the life of the lease.

The IFRIC decided that, notwithstanding the fact that a close reading of IAS 17 could suggest an alternate treatment, there was no evidence of diversity in practice, which was to exclude contingent rent from the estimate of total lease payments/ income. Consequently, the IFRIC declined to take this issue to its agenda.

Customer Loyalty Programmes

The IFRIC discussed the first draft of a Draft Interpretation on customer loyalty programmes. In March, the IFRIC Chairman had directed the IFRIC staff to develop the draft on the basis of recognising a separate component of the initial sales transaction in which the award credits are granted as representing the unperformed performance obligation. Under this approach, some of the consideration received for each initial sale would be allocated to the award credits.

The IFRIC spent a considerable amount of time discussing the tension between IAS 18 paragraphs 13 and 19, and several IFIRC members were not satisfied that the Draft Interpretation explained adequately the approach inferred by IAS 18 paragraph 13 should be used to the exclusion of that in paragraph 19. The debate was concluded by the Chairman, who asked whether there was sufficient support for the approach in the Draft Interpretation. Two IFRIC members would oppose the document. On this basis, the Chairman directed the staff to proceed with the approach as adopted, but to work with those who were opposed to the approach to ensure that their concerns were reflected adequately in the Basis for Conclusions.

Scope

The IFRIC agreed with a staff proposal that the scope of the Draft Interpretation need not be defined rigorously and should not specify scope exclusions.

Awards supplied by third-party providers

The IFRIC held an inconclusive discussion on how to account for awards supplied by third parties. The IFRIC was concerned that the Draft Interpretation should not confuse agency relationships with sub-contracting: that is, who is providing the service. The IFRIC discussed a staff example, which demonstrated that the measurement of these awards is also problematic. The IFRIC will continue its discussions of this topic at a later meeting.

Separate component approach

The IFRIC discussed the justification for the separate component approach in the draft Basis for Conclusions (not available to Observers). However, it was apparent that part of the justification was based on SIC 15, an Interpretation of IAS 17. IFRIC members criticised the prominence awarded to an interpretation of a leasing standard in an Interpretation of IAS 18.

Next steps

At its next meeting, the IFRIC will discuss an amended version of the Draft Interpretation.

Larry Smith, Chairman of the FASB's Emerging Issues Task Force, attended the meeting. He noted that the EITF had attempted to issue an Abstract on this issue and had been unable to reach consensus.

It should also be noted that three IFRIC Members who did not object to the Draft Interpretation were attending their last meeting. How their successors vote could be critical to the future of the direction of this issue.

IAS 19 Post-employment BenefitsThe effect of a minimum funding requirement on the asset ceiling

The IFRIC continued its discussion of how the additional liability resulting from a minimum funding contribution requirement should be presented in the financial statements. The staff noted that this additional liability arises only because of the limit on the measurement of the balance sheet asset in IAS 19.58.

Presentation of results

The staff noted that IAS 19.58 governs the presentation of the net balance sheet position in the pension plan rather than the gross liability. The staff proposed that the adjustment which results from the impact of the limit in that paragraph should be recognised and presented in the financial statement on a net basis. There was general agreement with the staff proposals.

Treatment of future minimum funding contributions payable

The IFRIC discussed a staff recommendation that the additional liability to be recognised in respect of such a minimum funding requirement was equal to the present value, using IAS 19 assumptions, of the contributions payable in accordance with the minimum funding requirement. In addition, in some circumstances, a minimum funding requirement may also stipulate a schedule of future minimum contributions payable in order to cover the future accrual of benefits over the period during which the contributions are payable. In this case, the staff noted that the contributions payable in respect of future accrual did not generate an additional liability at the balance sheet date as they represented a future rather than a present obligation.

The staff suggested that the future minimum funding contribution requirements, in respect of future accrual, reduce the extent to which the entity can take a future contribution reduction. Therefore the available asset from a contribution reduction should be calculated as the present value of the IAS 19 service cost less the future minimum funding contribution requirement in respect of future accrual in each year. The IFRIC agreed with the staff's analysis and conclusion.

Other statutory funding requirements

The IFRIC agreed that the Interpretation need not address other statutory funding requirements.

Transition

The IFRIC generally agreed with the staff proposals for transition. However, it was evident from the discussion of the proposed Basis (not available to Observers) that individual members had concerns with how the Basis was drafted and suggested different matters of emphasis.

Next steps

The IFRIC Chairman asked for an indication of which IFRIC members would object to the Interpretation along the lines discussed. None indicated an intention to object.

The staff would was directed to prepare a revised draft Draft Interpretation and Basis for Conclusions with the intention that this would be approved formally at the July 2006 meeting. The staff will hold a public Education Session with the IASB during its June 2006 meeting.

Service Concession Arrangements

The IFRIC discussed a draft Interpretation based on D12 Service Concession Arrangements – Determining the accounting model. In summary, the IFRIC agreed:

  • Not to address sale and leaseback accounting in this Interpretation.
  • To include in the Interpretation an explanation of the reasons for the scope limitations and the reasons for the control approach adopted by the IFRIC. The IFRIC agreed to include additional implementation guidance (an appendix) explaining how other IFRSs might apply to concession arrangements for private sector performance of public services and for determining whether existing infrastructure of the operator was within the scope of the Interpretation.
  • To amend the scope of the Interpretation to include 'whole of life infrastructure' (infrastructure used in a service concession arrangement for the whole of its useful life).
  • To amend the approach in D12 to require that an entity should recognise a financial asset to the extent that the operator has a contractual right to receive cash from or at the direction of the grantor. A right other than a contractual right to receive cash does not meet the definition of a financial asset and is within the scope of IAS 38 Intangible Assets. This implies that some concession arrangements will be bifurcated – containing both a financial asset and an intangible asset.
  • To make a consequential amendment to IFRIC 4 to make explicit the boundary between IFRIC 4 and this Interpretation.
  • To adopt a new title for the Interpretation along the lines of Private Sector Participation in the Provision of Public Services. IFRIC members did not like the term 'participation' but agreed with the general idea (for example, 'Private Sector Operation of Public Services').
  • The accounting issues identified in Draft Interpretations D13 and D14 would be incorporated in D12 and issued as a single Interpretation.

The IFRIC discussed these issues in some detail. Unusually, the Observers were provided with the draft Basis for Conclusions (but not the draft Interpretation). IFRIC Members made detailed comments on the proposed Basis, and it is likely to be redrafted significantly before the individual IFRIC members are happy with it.

Significant residual value

The IFRIC agreed with a staff recommendation that Application Guidance should be added to specify the meaning of the term residual interest. The residual interest is the estimated value of the infrastructure at the end of the term of the concession, if the infrastructure were already of the age and in the condition expected at the end of the term of the concession. The staff had drafted a detailed rationale, but the IFRIC seemed to prefer a statement of the principle rather than providing the detailed explanation of how the IFRIC reached its conclusion (for fear of the rationale being applied to situations to which such a conclusion might not be appropriate).

Next steps

The IFRIC will continue its discussions of D13 and D14 at a later meeting.

This summary is based on notes taken by observers at the IFRIC meeting and should not be regarded as an official or final summary.

Comment deadlines on ED 8 and measurement paper

10 May 2006

We remind you that the deadlines for responding to both of the following IASB documents are Friday 19 May 2006: ED 8 Operating Segments.

ED 8 The proposed IFRS would replace IAS 14 Segment Reporting and align segment reporting with the requirements of FASB's SFAS 131 Disclosures about Segments of an Enterprise and Related Information.
  • Discussion Paper: Bases for Financial Reporting - Measurement on Initial Recognition The Paper analyses possible bases for measuring assets and liabilities on initial recognition.
  • ED 8 and the Discussion Paper may be downloaded from the IASB's Website.

    US GAO report on SOx impact on small public companies

    09 May 2006

    A report prepared by the United States General Accountability Office (GAO) found that small public companies (defined as market capitalisation under US$700 million) incur a disproportionate cost of compliance to implement Section 404 of the Sarbanes-Oxley Act of 2002 (internal control reporting) compared to large companies.

    GAO suggests that this may have been one factor in the reduced number of IPOs, increased number of companies 'going private', and shift among small companies from use of the largest audit firms, to mid-size and smaller audit firms. Examples cited in the report include:
    • Of the companies that reported implementing section 404, public companies with market capitalisation of $75 million or less paid a median $1.14 in audit fees for every $100 of revenues compared to $0.13 in audit fees for public companies with market capitalisation greater than $1 billion.
    • 81% of the small public companies that responded to the GAO survey had hired a separate accounting firm or consultant to assist them in meeting Section 404 requirements. Services provided included assistance with developing methodologies to comply with section 404, documenting and testing internal controls, and helping management assess the effectiveness of internal controls and remediate identified internal control weaknesses. These small companies reported paying fees to external consultants for the period leading up to their first section 404 report that ranged from $3,000 to more than $1.4 million.
    • The number of public companies that went private has increased significantly from 143 in 2001 to 245 in 2004, with the greatest increase occurring in 2003.
    The report includes recommendations for both SEC and PCAOB consideration, and comments from both of those organisations. Click to (PDF 1,012k), which is titled Sarbanes-Oxley Act: Consideration of Key Principles Needed in Addressing Implementation for Smaller Public Companies.

    SEC roundtable on interactive data

    09 May 2006

    The US Securities and Exchange Commission will host a public forum on ways that interactive data can improve disclosure for ordinary investors.

    The roundtable will be held at the SEC's Washington, DC, headquarters on 12 June 2006. Particular emphasis will be placed on disclosures by mutual funds. Interactive data permits Internet users to search for and use individual items of information from financial reports, such as net income, executive compensation, or mutual fund expenses. Topics to be considered at the forum include:
    • What investors and analysts are looking for in the new world of interactive data.
    • How to accelerate the use of new software that permits the dissemination of interactive financial data.
    • How best to design the SEC's requirements for company disclosures to take maximum advantage of the potential of interactive data.
    Click for (PDF 34k).

    Further steps toward convergence of securities regulation in Europe

    08 May 2006

    The Council of European Finance Ministers (ECOFIN) has adopted recommendations for further convergence of the supervision of the securities markets in the EU Member States.

    ECOFIN noted that "the growing number of cross-border financial groups and the increasing international and cross-sector interlinkages in the financial markets call for further progress in the convergence of supervisory practices and cross-border cooperation among supervisory authorities in the EU. The Council underlines that supervisory convergence needs to be intensified to fully benefit from the FSAP [Financial Services Action Plan] and related measures and thus, to reap the benefits of an integrated financial market." ECOFIN asked the Committee of European Securities Regulators (CESR), the Committee of European Insurance and Occupational Pensions Supervisors (CEIOPS), and the Committee of European Banking Supervisors (CEBS) to further strengthen their co-operation and day-to-day working arrangements. Click for:

    Comparison of Singapore GAAP and IFRSs updated

    08 May 2006

    We have updated the Comparison of IFRSs and Singapore GAAP on our Singapore page.

    You can find other comparisons of local GAAP and IFRSs Here.

    Comments invited on IFRIC due process

    07 May 2006

    The Trustees of the International Accounting Standards Committee (IASC) Foundation have invited public comment on the Draft Due Process for the International Financial Reporting Interpretations Committee (IFRIC).

    Comment deadline is 30 September 2006. To download the consultation document from the IASB's website Click Here (PDF 299k). Click for Press Release (PDF 44k).

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