Key features of the IVSC restructuring plan are as follows:

• IVSC remains a non-profit organisation incorporated in United States.
• IVSC acronym is retained but the name changed to the International Valuation Standards Council.
• The organisation will have three main bodies:
  • A Board of Trustees responsible for the strategic direction and funding of the IVSC.
  • A Standards Board appointed by the Trustees, but with autonomy over its agenda and the creation and revision of standards.
  • A Professional Board appointed by the Trustees to assist in the development of high quality practices by the world's valuers and development of the profession in developing countries.
• Membership of the IVSC will be broadened beyond national professional valuation institutes to include valuation companies, government, valuation end-users, and academia.
• Current IVSC directors remain in post for the transitional period November 2007 to May 2008, with responsibility for day to day management of the IVSC.
• During the November to May period, an advisory board, to be known as an interim Board of Trustees, will be established to oversee the IVSC restructuring process and business plan. Funds raised will be independently controlled by the group and released in accordance with the IVSC restructuring proposal. Michael Sharpe, former Chairman of the International Accounting Standards Committee, will be a Trustee. Mr Sharpe was also a member of IASC's Strategy Working Party that developed proposals leading to the creation of the IASB.

The key matters raised in the Deloitte letter on the SME ED are:

• The final Standard should be a fully stand-alone document. We support the objective of a self-contained, comprehensive, set of standards for SMEs and do not agree that the IFRS for SMEs should contain any cross referencing to full IFRS, with the exception of financial instruments, as discussed in Appendix C. We believe that SMEs should be able to find all their financial reporting requirements in the one stand-alone document.
• The IFRS for SMEs has not addressed the needs of SME subsidiaries where consolidated financial statements are prepared by the parent company in accordance with full IFRS. Such entities are likely to prefer to apply the same recognition and measurement principles as applied by the group but with reduced disclosure. We believe that such an option should be included within the IFRS for SMEs.
• Further simplification of the recognition and measurement principles is required. The needs of users of SME financial statements are not as sophisticated as those of full IFRS financial statements and therefore the accounting requirements should be simplified. This may include further elimination of options, and/or, alternatively, increasing divergence from full IFRS. The proposals also appear to have unintended consequences that make the ED, in some respects, more onerous than for those applying full IFRS.
• Further disclosure relief is required. Although we acknowledge that the ED proposes significant disclosure relief when compared to full IFRS, we believe this is a key area where simplification has not gone far enough. Further enhancements are possible without any risk of not satisfying the information need of users.
• Clarification that the IFRS for SMEs is not part of the IFRS hierarchy is required (possibly via an amendment to IAS 8). We are concerned that in circumstances where full IFRS is silent on a transaction, condition or event, users of full IFRS may be required to analogise to the IFRS for SMEs for guidance.

Advisory Committee issues that relate directly to IFRSs include:

• Consider whether and how training and continuing education relating to IFRSs and international auditing standards need to be enhanced.
• Consider the impact on the curriculum of the potential acceptance of IFRSs and international auditing standards.
• Consider the impact of IFRSs and international auditing standards on faculty resources and requirements.
• Consider how the potential acceptance of IFRSs in the United States and the greater use of fair value and mark-to-model accounting will impact the largest auditing firms' network of affiliates.
• Consider how the potential acceptance of IFRSs and international auditing standards will impact audit market competition.

On whether the SEC should accept IFRSs 'as adopted in the EU' And still I hear some voices who say this is a poor outcome [SEC dropping the reconciliation for those who use IFRSs as adopted by the IASB]. They think the SEC should have accepted an EU brand of IFRS along with IFRS as adopted by the International Accounting Standards Board or IASB. I am not sure if these critics suffer from amnesia. Let us not forget the facts here. We in Europe have decided to go for IFRS because we rightly believed in the virtues of having a single accounting language. And when I say 'we' I mean all of us, including the Council of Ministers and the European Parliament. We have been preaching this gospel to our US counterparts for the last five years – asking them with indefatigable stamina to accept IFRS. And we have been very successful apostles indeed. Not only has the US decided to accept IFRS for our firms, they even envisage allowing their firms to use them. So let us be serious here. We have got what we have been asking for. One hundred per cent.

On IASB governance and eliminating the need for EU 'endorsement' of IFRSs I spent the first 18 months in office fighting against those who wanted an EU standards setter because they were so unhappy with the IASB. Members of Parliament were lobbied in order to modify proposed standards. That is how we ended up with the carve-out for IAS 39. Since then, there have been improvements in IASB governance and more is needed.

One of the cornerstones of my strategy is that we must be able to accept any future standards without any serious problems. The endorsement of accounting standards needs to disappear from the political limelight. It should not necessarily be a high profile political issue. Therefore, we must make sure that the new standards reflect the real needs of stakeholders. In more concrete words, we need to have a close look at the standard setting process by the IASB: more transparency, better consultations, impact analyses at an early stage, thorough field-testing of any new standards to avoid unwanted or even unexpected consequences. But above all new standards only where they are really necessary – I shall be very vigilant on that in the future.

On acceptance of US GAAP in EU securities markets without reconciliation to IFRSs Now it will be Europe's turn to accept accounts in US GAAP. This decision will have to be taken next year. And it is certainly my intention to propose that no reconciliation to IFRS will be needed for companies filing their accounts under US GAAP. This is the only sensible way forward.

• Use of market-based data. We agree with an overall principle that all assumptions used should be market consistent, but only to the extent that references to market data are effectively available and relevant to include in the measurement of an insurance liability. If this not the case, the final Standard on insurance contracts should clearly state that an insurer will use 'portfolio-specific' data if available, and otherwise its own entity-specific data, to the extent that market participants would have included this type of data into the measurement of an insurance liability.
• Risk margins and service margins. We believe that the DP fails to provide a clear view of what are the risk and service margins. In addition, the DP fails to discuss properly the nature of insurance contracts and whether analogies should be made with service contracts.
• Day-one gains and losses. Once insurance liabilities have been determined using the 'three building blocks' (and taking into account our comments), a proper estimate of the performance obligations associated with the insurance contracts will have been performed. Accordingly, we agree that it is appropriate to recognise in profit or loss any difference that arises at inception of insurance contracts between the measurement obtained (less relevant acquisition costs) and the premiums received.
• Labelling of the measurement attribute for insurance liabilities. We disagree with labelling the measurement attribute for insurance liabilities as a 'current exit value'. We do not believe that that term appropriately portrays what the goal of the measurement should be, or that there should be a reference to a transfer value. Insurers cannot transfer their insurance liabilities to third parties freely and would generally not wish to do so. ...The usual way of settling an insurance liability is for an insurer to continue to fulfil its commitments until the obligation is extinguished.
• Unit of account. We consider it important that the final Standard on insurance contracts specifies clearly that the unit of account for estimating both expected future cash flows and the risk margin is the portfolio of insurance contracts.
• Estimates of future cash flows: policyholders' behaviour and participation. Consideration of policyholders' behaviour is a reality of insurance activities. We support an overall objective for the final Standard on insurance contracts that is to provide relevant information to the users of the financial statements, enabling them to predict the cash flows relating to insurance contracts that will flow to and from the reporting entity.
• Consistency of the requirements for insurance contracts with other Standards. We ....support pursuing the efforts undertaken so as to produce proposals for insurance contracts – in the not too distant future – that result in sound and relevant financial information for those contracts, enabling the users of the financial statements to better predict the future cash flows that will flow to, or from, the reporting entity. If a treatment is considered to best meet the objective that we indicate, but would create an inconsistency with other parts of the IFRS literature, we do not consider that this treatment should be rejected outright.