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We express serious concern about 30-day comment period

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10 Mar 2002

In a [PDF 11k] to IASB Chairman Sir David Tweedie and the IASC Foundation Trustees, Deloitte Touche Tohmatsu has expressed 'serious concern' about the shortness of the comment period on IASB's first exposure draft (ED) on an accounting issue, Amendment to IAS 19, Employee Benefits: The Asset Ceiling.

We said:

In an international environment, translation and solicitation of input at the national level by national accountancy bodies are required in developing replies to EDs. On top of that, the issue raised in the ED is a complex one, and one that has existed since IAS 19 took effect over three years ago. In this particular case, the proposal in the ED has broad implications for some of the fundamental concepts of IAS 19 - implications that respondents to the ED must consider carefully. We certainly do not see this as an issue that in any way justifies a 30-day comment period.

We believe that, as a matter of policy, IASB Exposure Drafts should have at least a 90-day comment period other than in an exceptional situation. Further, we believe that IASB should develop and articulate, as part of the Preface, criteria to identify such an exceptional situation.

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