We believe it would have been helpful if the discussion paper indicated the extent to which its content had been debated by the Board. We note that providing guidance on management commentary (MC) is a considerable leap from the standard-setting activities that have previously been undertaken by the Board, and we would have appreciated it if the document had suggested the extent to which the Board members themselves support taking this step.

In summary, we do not believe the development of an MC standard is an appropriate task for the IASB at this time, if ever. We believe that the desirable content of MC is driven by cultural factors and expectations about how companies should do business. We therefore consider that the form and content of MC should continue to be regulated by local or regional regulators. We believe that the amount of IASB staff and Board time that would be consumed by the project is not justifiable until such time as the Board has completed some of the more contentious projects currently on its agenda. Should this item become an active Board project in the future, we would strongly recommend that the IASB staff work with a selection of local regulators in developing the requirements.