May

SEC staff paper explores the 'condorsement' approach for IFRS adoption in the US

27 May 2011

A paper released by the Staff of the U.S. Securities and Exchange Commission (SEC) outlines one possible approach for the adoption of IFRS in the United States.

The Staff Paper explores the so-called "condorsement" approach suggested by Paul A. Beswick (Deputy Chief Accountant) at a AICPA National Conference in Washington, D.C. in December 2010 (see our earlier story).

The Staff Paper discusses the approaches to IFRS adoption used by various jurisdictions, noting the differences between 'convergence' and 'endorsement'. The paper concludes the "condorsement" approach is in essence an endorsement approach that would share characteristics of IFRS incorporation approaches with other jurisdictions. However, during a transitional period, aspects of the convergence approach would be used to address existing differences between IFRS and U.S. GAAP, including the retention of a U.S. standard setter (FASB), which would facilitate the transition process by incorporating IFRSs into U.S. GAAP over a defined period of time (e.g. five to seven years).

An extract from the Staff Paper is reproduced below:

Overview

At the end of [the transitional] period, the objective would be that a U.S. issuer compliant with U.S. GAAP should also be able to represent that it is compliant with IFRS as issued by the IASB. Incorporation of IFRS through the framework would have the objective of achieving the goal of having a single set of high-quality, globally accepted accounting standards, while doing so in a practical manner that could minimize both the cost and effort needed to incorporate IFRS into the financial reporting system for U.S. issuers. It also would align the United States with other jurisdictions by retaining the national standard setter's authority to establish accounting standards in the United States.

Role of the FASB in the United States

In addition to incorporating new IFRS amendments into U.S. GAAP, the FASB also would exercise its authority as the national standard setter when it found, based on its experience in the ongoing interpretation or application of IFRSs incorporated into U.S. GAAP, that supplemental or interpretive guidance was needed for the benefit of U.S. constituents. Under the framework, the FASB should initially address this situation by informing the IASB of the potential gaps in authoritative guidance and providing the IASB a recommended solution to address the practice issues, but ultimately, the FASB could conclude an acceptable solution is not reached or the issue is not being addressed in a timeframe consistent with the needs of the U.S. capital markets.

Accordingly, the FASB could exercise its authority in one or more of the following ways:

  • adding disclosure requirements to those specified by IFRS, to address U.S. circumstances in a manner consistent with IFRS;
  • prescribing which of two or more alternative accounting treatments permitted by IFRS on a particular issue should be adopted by U.S. issuers, to achieve greater consistency in U.S. practice; or
  • setting requirements compatible with IFRS on issues not addressed specifically by IFRS. In particular, the FASB could decide to carry forward certain such requirements that already exist in U.S. GAAP, with any necessary conforming amendments.

If the FASB were to exercise this authority, a U.S. "flavor" of IFRS could result. However, U.S.-specific circumstances for which the FASB would consider modifying IFRS should be similar to the circumstances in which the Commission exercises its authority to amend or add to the standards issued by the FASB and, therefore, modifications should be rare and generally avoidable.

The SEC is yet to make a decision as to whether and, if so, how, to incorporate IFRS into the financial reporting system for U.S. issuers. The Staff Paper notes it is not intended to suggest that the SEC has determined to incorporate IFRS or that the "condorsement" approach is the preferred or only possible approach. The Staff Paper also notes the SEC Staff is continuing to consider the possible mechanics and implications of an early-adoption option for U.S. issuers to use IFRS and how it would work in the context of the approach explored in the Staff Paper or otherwise.

The SEC is calling for comments on the Staff Paper by 31 July 2011. Click for access to the Staff Paper (link to SEC website).

Call for unmodified IFRS option in India

26 May 2011

IASB Board Member, Mr. Prabhakar Kalavacherla (PK), has called for India to consider allowing Indian companies the option of using full IFRS in financial statements.

In a speech given in his personal capacity at an 'IFRS Summit 2011' conference organised by Confederation of Indian Industry (CII), Mr. Kalavacherla noted the IASB strongly encourages outright adoption of IFRSs, as against convergence. He stated "there is quite a degree of surprise in many international settings, including at the IASB, about India's approach to convergence with IFRS".

As noted in our earlier story, the Indian Ministry of Corporate Affairs (MCA) has issued 35 Indian Accounting Standards (Ind AS), which are based on IFRSs, but include some changes ('carve-outs') which are noted in the appendix to each standard. Some of the carve-outs may prevent an entity following Ind AS from making an explicit and unreserved statement of compliance with IFRSs. The MCA has not yet notified the start date for the application of Ind-AS.

An extract from the speech follows:

Have these carve outs being discussed in a manner so that international community can benefit from... deliberations and perhaps change international standards? Why does India not present the basis of conclusions for its standards to argue its reasons for divergence with international standards? Does the outreach and feedback by the various stakeholders in India validate the divergence? How is the investor focus and interest kept in mind, and what is their participation?

...

So, to sum it up, I have two suggestions:

  • Give Indian companies the option of full IFRS while keeping the carve outs. Let the market decide what is correct. In five years, India can revisit the issue and see what should be done.
  • Let [India] get more actively involved in the global standard setting and for that CII needs to be more active.

Click for:

 

Change to meeting agenda for upcoming IASB meeting

26 May 2011

The agenda for the special IASB meeting in London on 31 May – 2 June 2011 has been changed.

The IASB only session on Asset and Liability Offsetting on Thursday 2 June has been removed from the agenda and the meeting time shortened to end at 4:30pm (London time).

A revised summary of the agenda for the meeting can be found here.

IIRC to publish Discussion Paper on Integrated Reporting in June

25 May 2011

The International Integrated Reporting Committee (IIRC) met in New York on Friday 13th May 2011. At the meeting, the IIRC reviewed a draft Discussion Paper on Integrated Reporting which is due to be published for public consultation in June.

The IIRC has not widely publicised the expected contents of the Discussion Paper at this stage. However, at a Australian Business Reporting Leaders Forum (BRLF) meeting held in Sydney on 11 April 2011, Paul Druckman (Co-chair of the IIRC Working Group and Chairman of the Executive Board of HRH The Prince of Wales Accounting for Sustainability (A4S) project) provided an update on the draft Discussion Paper which had been debated at an IIRC working group meeting in London in April

The minutes from the BRLF meeting (link to the Australian Society for Knowledge Economics website) outlined the current thinking which included, that at that time:

  • Integrated reporting is still evolving; it will require changes in behaviour and a change in the reporting regime. It is a new way of thinking and reporting against short, medium and long term strategic objectives
  • Integrated reporting is not combined reporting (of financial statements and corporate social responsibility reports), or additional. It is a new and integrated report
  • The objective is to publish the Discussion Paper in June for public comment, and Exposure Draft in 2012, and potentially a Standard in 2013 (subject to IIRC ongoing Governance debate)
  • In addition, it is expected that a pilot program will run in parallel to trial aspects of the proposed framework over two years – to ensure it is pragmatic and doable.

The IIRC is working towards presenting an integrated reporting proposal to the G20 later in 2011.

Click for:

 

IFRS Foundation publishes Russian translations

25 May 2011

The IFRS Foundation has announced the publication of Russian translations of:

  • the requirements of every IFRS as issued (eIFRS/comprehensive subscriber access only)
  • requirements of the International Financial Reporting Standard for Small and Medium-sized Entities (IFRS for SMEs) 2009 (available to all registered users of the IASB's website).

The translations where foreshadowed in our 10 November 2010 article and are designed to support IFRS adoption in Russian-speaking countries. In February 2011, the Russian government signed off an IFRS endorsement procedure whereby IFRSs will be endorsed for use in Russia by the Ministry of Finance (see our earlier story).

The Bruce Column — Stretching standard time

23 May 2011

Standard-setting activity has been positively thundering along.

The great batch of five new standards just published is compelling evidence of this. The fair value measurement achievement was probably the greatest. The glare of publicity and discussion made it the focus of attention. But they still managed to deliver a good converged standard. But the question remaining is whether it will succeed in the long run, and whether the convergence programme can provide further results. Sir David Tweedie retires at the end of June. And now the agenda has changed. The new plan talks of final standards on financial instruments: impairment, hedge accounting and asset and liability offsetting by the third quarter of the year; final standards on leases, revenue recognition and insurance contracts by the fourth quarter, and so on. There are only seven months of the year to go, less if you factor in the bureaucratic side of getting a standard out.

We are back to the central problem of convergence. The difficulty of completing a convergence programme is, frankly, the specific difficulty of convergence itself. Best intentions can be signalled early in the process. People can work all the hours there are. But good arguments on both sides and the difficulties they create may still remain, however much people urge convergence all round. This is the problem that the IASB and FASB have had since the outset of their convergence programme. It creates expectations that different standards on the same topic can be harmonised and brought together. But deadlines are what you fall over.

Part of the problem has been the steady realisation during the programme of how much needed to be done not so much to sort out differences but to raise the quality. As the IASB Chairman, Sir David Tweedie, said last month in an assessment of the nine years so far of the convergence programme, if the standards were 'complex or out of date there was no point in trying to converge them otherwise we would just get a complex out-of-date converged standard when what we should really do is write a better standard'.

And there, in a nutshell, is the problem. Pulling two sides of the standards together was just as likely to result in something which compounded the problem as it was to provide enlightenment and simplicity. Much better to use the experience gained to make something new, effective and useful. Where this works everyone is better off. As Sir David went on to say: 'The two sets of standards are much closer together and frankly IFRSs are much better quality than they would have been otherwise'.

In the same interview Sir David's counterpart at the US FASB picked up on this point. Leslie Seidman stressed that there had been 'very significant convergence efforts'. But it was what was left which may require time to become elastic. 'What we have got left', she said, 'is a few priority projects including leasing, revenue recognition, financial instruments and insurance, and that is what we have been focusing on'.

But those four projects have already consumed a huge amount of work, (no one who has witnessed the marathon board meetings and the hours worked by the project staff will dispute the adjective huge), and outreach and consultation. But equally no one suggests we are in sight of a conclusion or, in the case of the more intractable issues, a solution. The original deadline for much of this work was the end of June this year, which coincidentally is also the point when Sir David's decade of tenure as Chairman comes to an end.

Instead the deadlines are being steadily pushed back. But the interesting point is that they are not simply being pushed back because the technical issues are taking longer to sort out. There is another issue. As the Investment Management Association made clear in a response made earlier this year: 'The focus on convergence at all costs consumed resources that could have been used in the development of high quality standards'.

This is what is new. And this is why even the rest of 2011 may not be enough to complete this work. Quality should now be the watchword. And quality does not come about simply through upping the workload. It also depends on thought and feedback. Leslie Seidman said as much back in the April interview: 'The quality of standards remains of the utmost importance'. And Sir David emphasised the point. 'What we have done', he said, 'and I think this is a big change in standard-setting over the past couple of years, is we have gone out deliberately to get high quality input in addition to that required by our due process. This extensive outreach is something that hadn't been done to the extent that it is now. We get constant input, and we test these ideas as we finalise the standards'.

So as we watch the programme unfold with the re-deliberation on ideas on, for example, leasing, insurance and impairment, we should not be surprised if the deadline for completion slips further and further back. What is needed is the sort of quality which will ensure stability and consistency in an issued standard. The key is still time. But it is the future longevity and the shelf life of the standard, not the time it takes to produce, to which people will be looking most closely.

Robert Bruce
May 2011

Related links

 

 

Strategy Review comment letters analysis

23 May 2011

The Trustees of the IFRS Foundation, the oversight body of the International Accounting Standards Board (IASB), have posted to their website a summary strategy review response analysis.

The paper analyses the feedback received in response to the Foundation's public consultation paper Status of Trustees' Strategy Review, which was issued on 5 November 2010. It is based on an analysis of respondents' comment letters and follows the summary document that was published in April. The deadline for comment letters on the summary document is 25 July 2011.
Click for:

 

Agenda for IASB special meeting on 31 May – 2 June 2011

23 May 2011

The IASB is holding a special meeting in London on 31 May – 2 June 2011, much of which is a joint meeting with the FASB.

You can access the agenda on our May 2011 IASB meeting page.  We will also post Deloitte observer notes on this page as they are available.

IFAC CEO discusses the need for transparency in government financial reporting

20 May 2011

At a recent conference, Ian Ball, Chief Executive Officer of the International Federation of Accountants (IFAC), discussed the importance of transparency in government financial reporting.

In speech given to the World Bank Government Borrowers Forum held in Santiago, Chile on 11 May 2011, Mr Ball noted that investors in government securities should be entitled to essentially the same high-quality financial information as they receive in relation to investments in corporate bonds or equities.

In responding to the need for greater transparency, Mr Ball notes that a number of countries are moving towards the adoption of International Public Sector Accounting Standards (IPSAS) or other accrual-based accounting systems. An extract from the speech follows:

What would a set of financial reporting standards look like for governments? Without seeking to give a comprehensive answer... some obvious points are:

  • Cash based accounting, though still commonplace even in developed countries, is simply inadequate. That is why GFS [Government Finance Statistics] is in principle on an accrual, not a cash, basis. It is why companies listed on every capital market are required to report on an accrual basis. The cash basis fails to provide sufficient information to enable a reasonable assessment of financial performance or position
  • The entity should include in its financial reporting all the activities or sub-entities that impinge on its position and performance, and the associated risks – including all governmental financial institutions and all commercial activities
  • Unless there is a good public sector specific rationale for a different treatment, an asset, liability, revenue or expense, should be accounted for in the same way as it is in the private sector.

Click for access to the full transcript and presentation slides (link to IFAC website).

Final notes from the regular May IASB meeting

20 May 2011

The IASB held its regular monthly meeting in London on 17-19 May 2011, much of which was a joint meeting with the FASB.

We've posted the remaining Deloitte observer notes of the meeting (click through for direct access to the notes for each topic):

Thursday, 19 May 2011 (IASB/FASB) (other sessions)

  • Leases
  • Lessee Accounting Approach
  • Lessor Accounting Approach
  • Distinguishing Between Lease Types
  • Contract Modifications or Changes in Circumstances
  • Options in a Lease
  • Discount Rate in a Lease

Click here to go to the preliminary and unofficial Notes Taken by Deloitte Observers for the entire meeting.

Correction list for hyphenation

These words serve as exceptions. Once entered, they are only hyphenated at the specified hyphenation points. Each word should be on a separate line.