Jointly, we have a window of opportunity to facilitate the smooth integration of China, India, Brazil and others on the world economic stage. The EU and the US should lead by example and show how open and competitive markets with sound standards of investor and consumer protection can deliver a thriving transatlantic financial market place. In accounting, in auditing, in our securities and other markets the EU and the US can make a special contribution to the emerging global regulatory system. If we cannot resolve our differences, what sort of example are we giving to the others? This is a question of mutual interest and leadership.

• Pensions: The staff recommends the accounting guidance for defined-benefit pension plans and other post-retirement benefit plans be reconsidered. The trusts that administer these plans are currently exempt from consolidation by the issuers that sponsor them, effectively resulting in the netting of assets and liabilities in the balance sheet. In addition, issuers have the option to delay recognition of certain gains and losses related to the retirement obligations and the assets used to fund these obligations.
• Leases: The staff recommends that the accounting guidance for leases be reconsidered. The current accounting for leases takes an 'all or nothing' approach to recognizing leases on the balance sheet. This results in a clustering of lease arrangements such that their terms approach, but do not cross, the 'bright lines' in the accounting guidance that would require a liability to be recognized. As a consequence, arrangements with similar economic outcomes are accounted for very differently.
• Financial instruments: The staff recommends the continued exploration of the feasibility of reporting all financial instruments at fair value.
• Consolidation: The staff recommends that the Financial Accounting Standards Board continue its work on the accounting guidance that determines whether an issuer would consolidate other entities – including SPEs – in which the issuer has an ownership or other interest.
• Disclosures: The staff believes that, in general, certain disclosures in the filings of issuers could be better organized and integrated.

The government grants project had started as part of the IASB's short-term convergence project with FASB. However, it has evolved into a stand-alone (non-convergence) IASB project to reconsider IAS 20 Accounting for Government Grants and Disclosure of Government Assistance. The stated objective of the project is to amend IAS 20 by applying the accounting model for government grants contained in IAS 41 Agriculture to all government grants. The IAS 41 model establishes the following principles for recognising grants related to assets measured at fair value through profit and loss:

• If the grant is unconditional, recognise income when the grant becomes receivable.
• If conditional, recognise income when conditions attached to the grant have been met.

In the interim reports reviewed, most issues arose on matters where there had been changes as a result of the implementation of IFRS. These largely related to the presentation of items within the primary financial statements and to narrative descriptions of new or revised accounting policies.

Take auditing for example. The EU has just put the finishing touches to its new directive on Statutory Audit (the 8th Directive). During its implementation one of the key challenges will be the question of registration of third country audit firms in the EU by 2008. All third country audit firms, including US ones, auditing foreign companies listed in the EU will have to be registered with EU oversight bodies - unless their home country oversight bodies can be considered as equivalent.

Similarly, EU firms auditing SEC registrants will face inspections from the PCAOB in 2006 and 2007. The new EU directive provides for cooperation with the PCAOB on access to audit working papers. These are tricky issues where the EU and the US must have close and pragmatic cooperation or willingness to 'agree to agree' as Bill McDonough, former chairman of the PCAOB, put it. Both sides have to deliver. And both sides must be willing to respect each other's rules and limitations. Deepening cooperation is the name of the game.

EFRAG wants to express its full support for the comments you made in your introduction to the Board's deliberations at the January meeting where you indicated that:

• (a) the direction in which the project is presently heading under Board members' guidance is leading to a standard which appears far too lengthy and complex; and
• (b) more simplifications are needed than decided up to date in order to meet constituents' expectations.

We agree with this view. We think it is important that the IFRS for SMEs is easy to understand and comprehensive on a stand-alone basis.