The Conceptual Framework Bulletins are intended to promote discussion and to inform about European views on the IASB's Conceptual Framework project where a discussion paper is due to be released in July 2013. The first three issues were dedicated to the concepts of prudence, the reliability of financial information, and uncertainty.
On the Conceptual Framework bulletin on prudence, FEE comments that "in itself, prudence should not be considered as a primary factor in the development of accounting standards". FEE suggests limiting the role of prudence in the development and in the application of accounting standards to a general exercise of caution and believes that the IASB Conceptual Framework would benefit from explaining the relationship between prudence and neutrality.
Regarding the Conceptual Framework bulletin on uncertainty, FEE agrees with the Bulletin’s tentative conclusion that uncertainty is not only a matter of measurement and that a probability-based threshold should be retained as part of the recognition criteria of assets and liabilities.
On the Conceptual Framework bulletin on the reliability of financial information, FEE agrees that reliability (including the idea of verifiability) needs to be reinstated as a fundamental characteristic of information in financial statements as FEE believes that "reliability" is a broader notion than the concept it was replaced with ("faithful representation").
You can access all comment letters on the FEE website: