We wish to acknowledge that in our opinion, the proposed Framework as expressed in the ED has been significantly improved from the Discussion Paper phase of this project. We find the proposed Framework is now well organised and we generally agree with the notions expressed therein. More specifically, we agree with the dual focus of the expressed objective of financial reporting on both cash flow generation and management stewardship and also agree that decision useful information has several qualitative characteristics of which relevance and faithful representation are the most fundamental. However, we think that comparability, verifiability, timeliness and understandability are supporting components (not 'enhancing characteristics') that need to be present to render financial information relevant and representationally faithful. In addition, there are certain aspects of the proposed Framework which we continue to believe may be enhanced. We have included our comments on these aspects in the Appendix to this letter....

We believe that the individual chapters of the conceptual framework should not be finalised (or at least not made effective) until all of the chapters are finalised to ensure that the overall Framework forms a cohesive set of principles.

Click to view Comment Letter on the IASB's Conceptual Framework Exposure Draft – An Improved Conceptual Framework for Financial Reporting (PDF 152k)