Deloitte comment letter on the IFRS Foundation Due Process Handbook
Deloitte's IFRS Global Office has submitted a letter of comment to the IFRS Foundation on the proposed IFRS Foundation Due Process Handbook that was published for public comment in May 2012.
In the comment letter, we agree with much of the content of the proposed Due Process Handbook. However, we disagree with incorporating into the Due Process Handbook amendments that have not been incorporated into the IFRS Foundation’s Constitution or the IASB’s Conceptual Framework as those are fundamental documents that may only be amended after a formal due process related to the documents themselves.
We also disagree with reducing the time period for re-exposure of proposed IFRSs or Interpretations as shortening re-exposure periods threatens the quality of IFRSs.
Finally, we are concerned that the Due Process Handbook is not entirely clear in relation to the roles, the responsibilities and the competences of the Trustees’ Due Process Oversight Committee and the IASB staff.