We call for a set of universally accepted standards for the disclosure to shareholders of climate change-related information1 connected to financial performance and to mainstream financial reporting.2 We propose that policy makers endorse collaboration between all relevant stakeholders to form an independent standard setter charged with achieving these goals.

We call on policy-makers to endorse the establishment of an independent, stakeholder-led standard setting body with appropriate accountability to public authorities, tasked with the development of a single set of universal standards for businesses to make climate change-related disclosures, linked to financial performance and mainstream financial reports. We believe that this will promote provision of more trusted, accurate and reliable information to investors and other stakeholders, thus enabling them to make better-informed decisions and drive the scale of behavioral change necessary to achieve a low-carbon economy.

To be eligible to voluntarily start using IFRSs in 2010, domestic Japanese companies must meet both of (1) and (2) below:

1. All of the following requirements shall be met:
   • Shares issued by the company are listed on a Securities Exchange in Japan.
   • The company discloses in its Annual Securities Reports information regarding specific efforts to ensure appropriateness of its consolidated financial statements.
   • The company allocates executives or employees with ample knowledge about Designated IFRSs and has in place a structure that enables it to properly prepare consolidated financial statements in accordance with Designated IFRSs.
2. The company, its parent, a related company, or the parent of the related company shall either:
   • disclose under laws and regulations of a foreign jurisdiction periodically as required thereby, documents on its business conditions prepared in accordance with IFRSs;
   • disclose under rules set by a foreign security exchange markets periodically as required thereby, documents on its business conditions prepared in accordance with IFRSs; or
   • own a foreign subsidiary whose capital is equal to or exceeds the equivalent of two billion Japanese yen.

This joint FEE-EFRAG paper firstly provides detail on the context of the recent IASB proposals and then goes on to give a general description of the expected loss model (including two worked computations). This high-level analysis is followed by a discussion about what information is generated by the model, including a description of how the results would be presented and disclosed in the financial statements and associated notes. Finally the Paper compares the expected loss model with other kinds of impairment models.... The aim of the paper is to provide general characteristics of the expected loss model, highlight the potential complexities and challenges, and stress the key differences from other models, rather than provide the assessment of its suitability, which would be provided in the comment letters to IASB by both FEE and EFRAG next year.

Just over a year ago, in a proposed 'roadmap', the Commission sought public comment on a proposed approach with respect to a possible path to greater use of IFRS in the US and suggested a number of milestones that the Commission might consider as important in making that evaluation. That public comment period ended in April of this year, and the staff has spent considerable time over these last few months focusing our attention on the very insightful input we received through that comment process, as well as evaluating potential courses of action....

While there are a number of operational, structural and transitional challenges that must be addressed, I believe the fundamental focus of our evaluation of implementing a set of high quality international standards must be on the impact to investors. I believe that implementing a single set of global accounting standards for US issuers can, and must, be done only in a manner that is beneficial to US capital markets and consistent with the SEC's mission of protecting investors. As we continue to evaluate such a monumentally important initiative, I believe we must carefully consider and fully understand and address issues, such as:

• US Investor understanding of and perspectives on IFRS;
• The development and application of IFRS for use as the single set of globally accepted accounting standards for US issuers;
• The impact on the US regulatory environment;
• Preparer considerations, including, among other matters, changes to accounting systems, changes to contractual agreements, corporate governance considerations, and litigation contingencies;
• Human capital readiness; and
• The role of the FASB in achieving the goal of a single global standard.