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FEE (Federation of European Accountants - Fédération des Experts-comptables Européens) (lt green) Image

FEE comment letter on proposed European Commission Directive

04 Mar, 2012

The Federation of European Accountants (Fédération des Experts-comptables Européens, FEE) has publicly released its comment letter on the European Commission proposal for a Directive on the Annual Financial Statements, Consolidated Financial Statements and Related Reports of Certain Type of Undertakings, including comments on amended Transparency Directive, which were released by the Commission on 26 October 2011.

FEE welcomes proposals aimed at better regulation and simplification, as well as reducing excessive and unnecessary administrative burdens. However, FEE comments that the Commission should "have considered and carried out a broader exercise focused on a more fundamental review to better adapt the Directives to 21st century accounting requirements characterised by principles-based standards and reflecting the dynamic developments in corporate reporting".

FEE also laments the lack of an option for European member states to permit the use of the IFRS for SMEs. An extract from the letter follows:

From a European perspective, FEE regrets that the Proposal does not seize the opportunity to allow Member States to make their own decision regarding IFRS for SMEs. It is unfortunate that this opportunity is missed because of differences in the accounting treatment of relatively minor matters between the Proposal and the current IFRS for SMEs.

FEE supports high quality and principles-based global standards in financial reporting, which promote consistency and transparency: we believe that IFRS for SMEs fulfils these characteristics particularly for larger SMEs and large unlisted entities.

The letter also comments on the proposed requirement for companies in the extractive industries and certain forestry companies to provide disclosures about their payments to government on a country-by-country basis, recommending these disclosures should be separate from the annual report, perhaps on company websites.

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Further notes from the February IASB meeting

01 Mar, 2012

The IASB is holding its regular monthly meeting on 27 February – 2 March 2012 in London, part of it a joint meeting with the FASB. We have posted Deloitte observer notes from some sessions held on Monday, Tuesday and Wednesday.

Click through for direct access to the notes:

Monday, 27 February 2012

Tuesday, 28 February 2012

Wednesday, 29 February 2012

Notes from the remaining sessions held on Tuesday and Wednesday will be posted soon.

You can also access the preliminary and unofficial notes taken by Deloitte observers for the entire meeting.

EFRAG (European Financial Reporting Advisory Group) (dk green) Image

EFRAG Update with summaries for January and February conference calls and the February 2012 EFRAG TEG meeting

01 Mar, 2012

The European Financial Reporting Advisory Group (EFRAG) has released the February 2012 issue of its 'EFRAG Update' newsletter.

The European Financial Reporting Advisory Group (EFRAG) has released the February 2012 issue of its EFRAG Update newsletter. On 26 January, 31 January and 8 February, EFRAG held meetings via public conference call. The EFRAG TEG meeting was held 22 to 24 February 2012. A highlight of the meetings was draft endorsement advices on IFRS 10, IFRS 11, IFRS 12, IAS 27 and IAS 28.

Click for the EFRAG Update (PDF 353k, link to EFRAG website). Links to earlier issues are available here.

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The Bruce Column — Words of Reassurance

01 Mar, 2012

The SEC’s Chief Accountant spoke frankly and personally at the recent IFRS Advisory Council meeting. Robert Bruce, our resident, regular columnist assesses what it means for the future of US, and global, financial reporting.

The word first appeared in December 2010. Paul Beswick, Deputy Chief Accountant at the US regulator, the Securities and Exchange Commission (SEC), invented it. In a speech at the AICPA conference outlining a possible approach to IFRS he said this: ‘In my opinion, if the U.S. were to move to IFRS, somewhere in between could be the right approach. I will call it a "condorsement" approach. Yes, I admit I just made up a word. And by the way, the patent is pending as we speak’.

Hold that patent. In comments to the IFRS Advisory Council meeting in mid-February James Kroeker, the SEC Chief Accountant, rowed back on the use of "condorsement" to characterise a possible move to IFRS in the US. A halfway house between convergence and endorsement was no longer being described. The word was not in the dictionary, he said. We shouldn’t make up words.

To many in his audience of senior members of the world’s IFRS community, this must have been encouraging. However, Kroeker remained as elusive as the SEC traditionally has been over whether and how to move the world’s largest economy from its traditional US GAAP financial reporting regime to IFRS, the one used by most of the rest of the world, might be made. ‘Hopefully we are on track for a few months time’, he said. And what does ‘few’ mean in this context? ‘More than a couple and less than many’, he said with a smile.

But the key message was that the SEC’s activities under their previously announced work plan are close to being completed, and a recommended approach will soon be issued as part of an SEC staff report. The worry has been that the SEC, with its astonishing rise in workload in the last year, might find that discussions about IFRS would slide back in importance and priority. Not so. But Kroeker explained some of the pressures which have led to delay. The decision to move ahead with the SEC workplan—involving consideration of the issues, a governance review and the status of convergence projects which would lead to an IFRS decision—was taken in February 2010. And then came the Dodd-Frank Act. Suddenly the gargantuan legislation to bring reform to the US financial markets landed in the SEC in-tray. Kroeker spelled out the details just in case we had underestimated the work involved. There were more than a hundred rule-making studies to be undertaken. It was ‘unprecedented in its magnitude’ since the creation of the SEC. It involved ‘tens of thousands of hours’ of work.

It had been no wonder that the timetable to produce a recommended approach had slipped. But Kroeker explained that ‘the decision last year to take a few additional months time should not be read as a negative indicator’. He said that the report was now in draft. And he praised the Monitoring Board of the IFRS Foundation for its publication, the week before, of its governance review. That was ‘the final point’ which they had been waiting for. The SEC report would be published in a few months time. And the SEC staff was working on a framework proposal. That is not to say that there weren’t challenging issues. Transitioning to IFRS from US GAAP would be complex to say the least. And you can see his point. The use of LIFO accounting in inventories or stock is tied deeply into US tax requirements. Changing to IFRS (which eliminated the practice years ago) would mean a loss of ‘somewhere north of $50 billion’, he said. The US corporate community would be likely to take a dim view. ‘That’, he said, ‘would be a $50 billion fight to have’. The challenges of rate-regulated accounting would have people ‘kicking and screaming’.

But, maintaining his optimistic message, Kroeker said that they would not want a handful of particularly challenging issues to hold up the issuance of the SEC report. ‘We may not align on Day One’, he said.

And the use of ‘US GAAP’ would continue. Inevitably it is embedded, as he pointed out, at multiple levels in the US system, federal, local, state, in regulations, in private party contracts, and so on. He drew a parallel with Canada. When they went for IFRS they retained the use of ‘Canadian GAAP’ so they could deal with the practical issues, engrained throughout the system, which arose.

Listening to the way Kroeker expressed his views, a possible scenario for US commitment to move to IFRS would be over a five-to-seven year timetable, on a framework applicable, eventually, to all public companies, with the FASB acting as the endorsement mechanism to ensure that future standards were in the best interests of US investors, and the SEC as the ultimate arbiter.

As for the option of companies using IFRS on a voluntary basis, this is still up in the air, but Kroeker seemed less warm to the idea of such an option, absent "a broader framework" for incorporation of IFRS into the US financial reporting system. In the context of such a framework, he said he could more easily see "getting there more quickly", although he wouldn’t call it "voluntary use", but rather in the traditional lingo of a standard setter, it would be more akin to "early election" rather than voluntary use.

Overall, those in favour of IFRS should be encouraged, but cautious. One of the longest and most drawn-out sagas of financial reporting does seem to be drawing to an end. However, uncertainty continues – at least for a "few more months".

EFRAG (European Financial Reporting Advisory Group) (dk green) Image
OIC (Italy Organismo Italiano di Contabilità) (lt blue) Image

EFRAG and OIC to hold outreach meeting on proactive discussion papers

29 Feb, 2012

The European Financial Reporting Advisory Group (EFRAG) and the Italian standard setter (Organismo Italiano di Contabilità, OIC) will hold an outreach meeting on 15 March 2012 in Milan regarding discussion papers Accounting for business combinations under common control and Improving the Financial Reporting of Income Tax.

The meeting is designed to gather feedback from users in Italy and neighboring countries on the topics developed in the discussion papers. The feedback will then be used by the EFRAG, OIC and the ASB in future work with the IASB that relates to income taxes and business combinations under common control. Registration is requested by 6 March 2012.

Click for EFRAG press release (link to EFRAG website).

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Additional roundtable on investment entities proposals to be held in the United States

29 Feb, 2012

The Financial Accounting Standards Board (FASB) has announced the FASB and International Accounting Standards Board (IASB) will hold an additional public roundtable meeting on Friday, March 16, 2012 to discuss the joint investment entities project.

The additional meeting has been scheduled to accommodate all interested participants and will be held from 1:30pm to 3:30pm (US EDT) at the FASB offices in Norwalk, CT. Discussion at the additional roundtable will be limited to the investments entities proposals and will follow the previously announced session being held on the same day.  The first roundtable is longer to allow discussion of the FASB’s exposure draft Real Estate — Investment Property Entities (Topic 973) which develops accounting guidance for entities focused on investing in real estate properties.

The additional roundtable was announced on the FASB's homepage (link to FASB website).

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Proposed revisions to Code of Ethics

29 Feb, 2012

The International Ethics Standards Board for Accountants (IESBA) has released proposed changes to the definition of "engagement team" in the IESBA 'Code of Ethics for Professional Accountants' (the Code) to avoid any perceived incompatibility between the Code and the International Standards on Auditing (ISAs).

The proposals address comments received by the International Auditing and Assurance Standards Board (IAASB) on its Exposure Draft (ED) on ISA 610 Using the Work of Internal Auditors. A number of respondents to that ED pointed out the perceived inconsistency between the independence requirements for external auditors under the Code and the use of internal auditors to perform external audit procedures. The proposed IESBA changes clarify that individuals in an internal audit function providing direct assistance to auditors do not meet the definition of the engagement team under the Code.

The proposals are open for comment until 31 May 2012. Click for IESBA announcement (link to IFAC website).

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Notes from the February IASB meeting

28 Feb, 2012

The IASB is holding its regular monthly meeting on 27 February – 2 March 2012 in London, part of it a joint meeting with the FASB. We have posted Deloitte observer notes from the impairment session held on Tuesday.

Click through for direct access to the notes:

Tuesday, 28 February 2012

Notes from the remaining sessions on Monday (insurance contracts) and Tuesday (insurance contracts and classification and measurement of financial instruments) will be posted soon.

You can also access the preliminary and unofficial notes taken by Deloitte observers for the entire meeting.

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IVSC to tackle valuation of derivative instruments

28 Feb, 2012

The International Valuation Standards Council (IVSC) has launched a project on the valuation of financial derivatives.

The types of derivative instrument that will be addressed by the project are equity derivatives, fixed income derivatives, credit derivatives, foreign exchange derivatives, commodity derivatives and hybrid derivatives. The intention is to examine the factors that influence the value of these instruments and how these are reflected in the models most commonly used for valuing them.

The IVSC Standards Board has formed an expert working group comprising of representatives of some of the major banks including UBS, Deutsche Bank and HSBC, independent consultants and buy side investors to advise it on the project.

An exposure draft is anticipated in the (Northern) autumn of 2012. Click for more information (link to IVSC website).

EFRAG (European Financial Reporting Advisory Group) (dk green) Image

EFRAG report on implementation of IFRS 10, IFRS 11 and IFRS 12

27 Feb, 2012

The EFRAG has issued a feedback report regarding field-tests on implementing IFRS 10, IFRS 11 and related disclosures in IFRS 12.

The field-tests were conducted by members of EFRAG and the European National Standards Setters. The tests were conducted in two separate questionnaires which gathered feedback from participates on issues arising from implementation of the new requirements and the estimate of expected costs and benefits preparers experienced.

Participants described certain benefits related to the implementation of IFRS 10 and 11, including (1) IFRS 10 provided "a single basis for consolidation and a uniform approach for all types of entities including 'special purpose entities'" and (2) IFRS 11 would eliminate "the existing accounting option for interests in jointly controlled entities."

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