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Deloitte comment letter on the IFRS Foundation Trustees’ review of structure and effectiveness

Published on: Dec 01, 2015

Deloitte’s IFRS Global Office has responded to the IFRS Foundation Trustees’ July 2015 request-for-views document with proposals for further enhancing the structure and effectiveness of the organization.

On the question of the IASB's remit, Deloitte’s IFRS Global Office also follows the cost argument and states that while not-for-profit organizations are within the IASB’s private sector scope, resources at the IASB are scarce and should be concentrated on work in the for-profit sector. However, Deloitte’s IFRS Global Office would support the IFRS Foundation Trustees assuming oversight (not standard setting) of activities in the public sector since many public sector entities are active in capital markets.

Deloitte’s IFRS Global Office disagrees with the proposal to reduce the size of the IASB to 13 members, because the IASB needs sufficient technical and standard-setting experience to have the ability to challenge the staff (and constituents) effectively. As it is, Deloitte’s IFRS Global Office already has a serious concern about the quality control over due process documents and issued IFRSs.

Finally, Deloitte’s IFRS Global Office thinks that what is missing from the consultation is a sense of context, how the IFRS Foundation Trustees see their current priorities in relation to a wider and more long-term view of financial and corporate reporting generally, and how and whether its structure and processes support that view.

Download the full comment letter below.


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