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Deloitte comment letter on the proposal to establish an Accounting Standards Advisory Forum

17 Dec 2012

Deloitte’s IFRS Global Office has submitted a letter of comment to the IFRS Foundation on its Invitation to Comment 'Proposal to Establish an Accounting Standards Advisory Forum'.

We support the proposal to establish an Accounting Standards Advisory Forum as being an appropriate means to utilise the technical skills and experience that exist in national and regional standard-setting bodies in the development and implementation of IFRSs. We encourage the Trustees to establish the Forum as quickly as possible.

We see the Forum as assisting the IASB to accomplish two distinct but related aims: the development of high-quality financial reporting standards; and assist in facilitating the incorporation/ endorsement of such standards without modification in the financial reporting framework of individual jurisdictions. We suggest establishing an objective for the Forum that clearly identifies these two aims.

For the composition of the ASAF we suggest engaging a network of national standard-setters, regional groups of standard-setters and bodies involved with standard-setting from those jurisdictions that have incorporated IFRSs into their financial reporting framework and those considering such an action. However, we do not fully agree with the form the ASAF is designed to have:

Whilst we recognise the desire of the IFRS Foundation to make the Forum an efficient body, we think that it is possible to achieve efficiency with a body of more than 12 members. As such, we do not support the explicit size and distribution of seats proposed in the Invitation to Comment, which we see as overly mechanistic and promoting (wittingly or unwittingly) a perception of exclusivity—something we see as undesirable.

Also, we suggest appointing co-chairs (one from the IASB and one from the other Forum members) as it would be a visible indicator of the collaborative nature of the Forum. We also think that Forum member organisations should be allowed to send other representatives than the designated representative if this seems helpful for particular technical discussions of the Forum.

We also point out that it is unclear who will appoint the Forum. The Invitation to Comment was issued by the IFRS Foundation Trustees, but is silent on whether the Trustees or the IASB will appoint members.

Click for access to the comment letter.