We have noted that in recent months the IASB has been working on an update of the existing IASB/FASB Memorandum of Understanding to incorporate new milestones covering the period to 2011.... As Europe is currently by far the biggest user of IFRS (in terms of companies), we are very interested in those priorities and in the IASB's work programme in general. We therefore thought it important to let you know our views on the issues discussed. Those views are set out in the numbered paragraphs that follow.

Issues discussed in EFRAG's letter include:

• Getting IFRS ready for the US and other countries transitioning to IFRS: The need for stability.
• The credit crunch: EFRAG recognises that, as a result of the current market turmoil, the IASB is carrying out a lot of work over a very short space of time and that this work has to be given a high priority.
• Balance the work programme between needs of Europe and other jurisdictions: 'The key issue for jurisdictions like Europe in these circumstances is whether an appropriate balance has been achieved between the interests of those jurisdictions using IFRS and those that are currently not using IFRS. There are several aspects of the work programme that concern us in this respect.' EFRAG is concerned about:
  • De-emphasis of the insurance project
  • Placing 'US views above the views of other jurisdictions'
  • Implementing views on fair value measurement 'without even being redebated'
  • The IASB limiting its consideration of the distinction between liabilities and equity to the three approaches mentioned in the recent FASB Preliminary Views document.
• Cross cutting issues: The IASB should allocate resource to addressing cross-cutting issues and should not cut back its work on the Conceptual Framework. These must be resolved before the IASB can decide on measurement, the difference between equity and liabilities, and revenue recognition.
• Discontinue work on the projects formerly known as the short-term convergence projects: 'In our view the projects will achieve relatively little but will be resource-hungry because they are relatively controversial'.
• Special-purpose entities: The IASB should look beyond FASB's FIN 46R for principles that can be used to account for SPEs.
• IASB comment documents: 'It is clear from the revised Technical Plan that the IASB will need to issue consultative papers and final documents at an almost unprecedented rate over the next few years. This will undoubtedly place a strain on the IASB's constituents. We would encourage the IASB to do all that it can to help constituents cope with that burden. Advance warning about publication dates and careful selection of comment deadlines and effective dates will all help ease that burden.'
• Public consultation on the IASB's agenda decisions: IASB should consult.