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Business Combinations Under Common Control (BCUCC)

Date recorded:

Agenda Paper 23

In previous meetings, the Board agreed a Discussion Paper will be drafted and it is expected to be published in November 2020. This paper asked the Board to set the comment period for the discussion paper.

Staff recommendation

The staff recommended allowing a comment period longer than the minimum comment period (usually 120 days) for the forthcoming discussion paper. This would:

  • (a) allow debate to mature and give stakeholders sufficient time to draw up high-quality feedback that is more likely to be based on a thorough consideration and discussion of the Board’s preliminary views rather than just on instinctive reactions reflecting particular entities’ existing practices;
  • (b) allow stakeholders to better manage their schedules and allocate their resources given that the Board expects to consult on a number of projects in 2020–2021 (including, for example, Rate-regulated Activities, Management Commentary, the 2020 Agenda Consultation and the Post-implementation Review of IFRS 10, IFRS 11 and IFRS 12); and
  • (c) further alleviate potential constraints on stakeholder resources brought by COVID-19.

The staff recommended that the Board allows a comment period of 180 days. The staff think that this would give stakeholders sufficient time to develop and submit well considered comments on the Board’s preliminary views.

Board discussion

The Board reiterated the point they have made previously that they do not want to make the 180-day comment period the default period. However, they acknowledged that these are not normal times, both in terms of COVID-19 and a peak in consultations.

Board decision and next steps

12 of the 13 Board members agreed with the staff recommendation to allow a comment period of 180 days.

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