October

CESR sees improvements in financial instruments disclosures

26 Oct 2010

In October 2009, the Committee of European Securities Regulators (CESR) analysed the 2008 financial statements of 96 European listed banks and insurers to assess compliance with the disclosure requirements of IFRS 7 Financial Instruments: Disclosures.

The results of the study highlighted that compliance could be improved in certain areas to enhance the transparency of financial communication to the market.

CESR has continued to monitor closely developments in relation to the reporting of financial instruments, including actions taken by different EU enforcers in respect of the accounts that were reviewed last year. In a follow-up report published today, CESR reports improvement in all monitored areas. The most significant increase in the level of compliance relate to: valuation techniques, own credit risk, credit risk, day one profit or losses and special purpose entities. A high level of compliance is also reported in respect of the new requirements relating to fair value hierarchy, mandatory for the first time in the December 2009 accounts.

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The Bruce Column — Around the table: the arguments over leasing

26 Oct 2010

There are several schools of thought evolving around the proposed leasing standard but the overwhelming one evokes the old joke about the farmer, leaning on a gate in the depths of the countryside, who is approached by a driver who wants to know how to get to his destination.

"If I were you", says the farmer, "I wouldn't start from here".

And that was where a recent debate between members of the UK Hundred Group of Finance Directors and members of the IASB began. There was a simple question about the standard: "Why now?" There were other arguments about the sheer scale of change which will be involved, the expensive and cumbersome changes to systems, and technical arguments. But it was timing which was uppermost in people's minds. No one really was arguing that change was not necessary. What they were arguing about was that in the midst of a precarious economic period replete with all the rethinking, restructuring, and uncertainty, they really didn't want to be introducing and implementing something which, while necessary, they saw as being a long way off urgent. People were supportive of the theory but felt that cost/benefit considerations and the practicalities involved ought, at this time, to outweigh the gain of attaining purity of theory.

There speak the preparers of accounts, always looking to the practicalities of implementation. But standard-setters have a different remit and know that with a controversial issue like leasing there will never be a good time to broach the subject. And that is what they argued. The process of trying to get to grips with leasing predated the founding of the IASB. It was a process of evolution. The informal G4+1 group of standard-setters had started work on this in 2000. "So", as Board member Stephen Cooper made clear, "this has been thought about for a long time". And the point in time when the thinking comes to fruition is not determined by a particular point in the economic cycle. "We can't make our judgements depending on the economic cycle", said Cooper, though he did suggest that they could take that into account when deciding on the date when the eventual standard takes effect.

The other argument is over whether you could achieve the desired transparency for users and investors by simply improving disclosure requirements and so saving preparers from the upheaval of change. This too failed to convince the IASB. Disclosure was not going to be a substitute for providing primary information in the financial statements. The topic of the recognition of assets and liabilities was not going to be fudged. As Board member Patrick Finnegan put it: "The Board doesn't agree with just increasing disclosure in the notes. That is not the way to improve the accounting", he said.

A straw poll of the audience showed that the majority there agreed that in theory all leases should be on the balance sheet. But the doubt over whether this was the appropriate time to be doing it lingered. One heartfelt intervention pointed out that preparers had suffered the impacts of changes involving pensions, healthcare plans and share-based payments and why did leases have to come into the same timeframe. Stephen Cooper was not giving any ground on this one. "We are not unaware of the social consequences of our work", he said. "But ultimately our mandate is to improve financial reporting and reflect the economics as fairly as we can".

Again he emphasised that the effective date would be at least 18 months after publication of the standard. There was then a riposte from the audience. The cat was already out of the bag they argued. Just having the proposals out in the public domain meant that analysts were already asking questions about the likely effects on their figures.

After this the questioning turned to short-term leases and the practical issues involved. And this was when photo-copiers started to bulk large in the arguments. When it comes to dealing with lease and other components in service contracts should you split out the photo-copier, the paper and the toner, one CFO asked. The answer from the IASB was that surely materiality would come into this. To which the response was that this was all very well with fixed assets. Fixed assets were tracked through systems. But, suggested a preparer, you don't do that for small items. Fixed assets went through a procurement process. Smaller items did not and so you were more prone to errors on low ticket items. And as someone else pointed out you could easily risk spending 50% of your time on 1% of the balance sheet.

Through all the arguments in the session the same central theme held sway. The theory was fine but the practicalities could prove impossible. When the discussion moved to considering options to extend or terminate a lease one exasperated finance director wanted to know if the several million company cars in existence would all need their lease terms to be continually reassessed. And when the concept of contingent rentals came to be discussed the same question of the enormity and reliability of the task involved came to the fore. One finance director argued that not everyone is a technical accountant. The people involved in this process of preparing and gathering the mass of data would tend to be operational people rather than technical accountants and that, for him, created a concern about getting high quality information.

These are early days in the debate. But time is short. And Stephen Cooper acknowledged this. He asked the audience to get their opinions in well before the official deadline of mid-December. His message was that leasing was an extremely challenging topic but the key now was for everyone out there to think about the issues and, if they had serious points to make, to get on the phone or send an email. The IASB is obviously expecting a difficult ride on this topic and are making real efforts to hear about solutions, or the existence of further unseen problems, early in the process. It is all going to be complex, and it is going to be hard work.

Robert Bruce
October 2010

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G20 Finance Ministers and Central Bank Governors push for global standards and consistency

25 Oct 2010

A Communiqué has been issued from the meeting of the G20 Finance Ministers and Central Bank Governors held in Gyeongju, Korea on 23 October 2010.

Whilst the key outcomes from the meeting concern reform of the International Monetary Fund (IMF) and avoiding so-called "currency wars", the Communiqué also discusses the consistent global implementation of accounting, banking and regulatory standards. The Financial Stability Board (FSB) had previously met on 20 October 2010 to discuss key elements of these financial reforms.

An excerpt from the Communiqué follows:

We are committed to take action at the national and international level to raise standards, so that our national authorities implement global standards consistently, in a way that ensures a level playing field and avoids fragmentation of markets, protectionism and regulatory arbitrage. To build a stronger global financial system, we have agreed to prioritize the following issues on the agenda for the Seoul Summit:

  • Welcome and commit to fully implement within the agreed timeframe the new bank capital and liquidity framework drawn up by the Basel Committee and the Governors and Heads Of Supervision
  • ...
  • Commitment to implement all aspects of the G20 financial regulation agenda, in an internationally consistent and non-discriminatory manner, including the commitments on OTC derivatives, compensation practices and accounting standards and FSB principles on reducing reliance on credit rating agencies...

The FSB press release discussing the FSB meeting on 20 October 2010 notes the following in relation to accounting convergence:

Accounting convergence. The FSB recognised progress toward improved, converged accounting standards in four main areas: impairment of financial assets; derecognition; addressing valuation uncertainty in fair value measurement guidance; and netting/offsetting of financial instruments. The FSB reaffirmed its support of standards that do not expand the use of fair value measurement recognition for lending activities, a position echoed by the comments of many investors and other stakeholders, and expressed hope that the FASB and IASB consideration of stakeholders' comments on proposed standards will result in improved and converged approaches. More generally, the FSB encourages the IASB and FASB to continue their efforts to achieve improved converged financial instrument accounting standards by June 2011.

The G20 World Leaders' Summit will be held in Seoul, Korea on 11-12 November 2010. Click for:

 

Deloitte comment letter on the IASB's removal of fixed dates exposure draft

25 Oct 2010

Deloitte's IFRS Global Office has submitted a letter of comment to the IASB on exposure draft ED/2010/10 Removal of Fixed Dates for First-time Adopters.

The proposal would amend IFRS 1 by replacing references to a fixed transition date of 1 January 2004' with the date of transition to IFRSs'.

We agree with the Board's proposal and its justification articulated in the Basis for Conclusion.

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Spanish IFRS in Focus on transfers of financial assets

25 Oct 2010

We have posted the following Spanish language IFRS in Focus publication from Deloitte (Colombia).

IASB und FASB decelerate three projects

25 Oct 2010

During their joint meeting in October 2010, the IASB and the FASB deliberated the projects Reporting Entity (Conceptual Framework, phase D), Financial Statement Presentation and Financial Instruments with Characteristics of Equity (Liabilities and Equity) against the background of the Boards' entire work plan.

Both boards concluded that all three projects deserve much more attention than the current Boards' capacity allows. As a consequence, in the view of the IASB and the FASB, the deferral is inevitable, though changes to the work plan have not been decided by the boards yet.

In particular, the project on Financial Instruments with Characteristics of Equity which attracted much attention from constituents in Germany and New Zealand seems to have been sidelined. Thus, neither targeted changes to IAS 32 (e.g. puttable instruments, convertibles, and non-controlling interest) – as signalled recently – nor a proposal of a fundamental new classification principle for equity can be expected before June 2011.

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New Heads Up on PCOAB Standing Advisory Group meeting

25 Oct 2010

Deloitte (United States) has released a Heads Up summarising the meeting of the PCAOB's Standing Advisory Group (SAG) held on 13-14 October 2010.

The meeting discussed the following: designing and implementing a firm system of quality control, FASB projects and their potential impact on auditors, and potential PCAOB rulemaking regarding the failure to supervise. In addition, the PCAOB provided an update on recent PCAOB developments and on its standard-setting activities.

The following extract from the newsletter discusses the impact of more principles-based accounting as the FASB and IASB work together on joint projects and the United States considers IFRS adoption:

There was considerable debate and discussion regarding the increase in judgment that will be expected of both issuers and auditors as a result of the more principles-based approach the FASB is taking in the accounting standards. The discussion included the following observations:

  • Increased judgment results in a need for increased documentation to support those judgments. Some suggested that the SEC should explicitly require such documentation by issuers.
  • Some suggested that issuers need a judgment framework to help them make accounting decisions. Others believed that a similar judgment framework should also be developed for auditors, although there was some disagreement on this point.
  • Some cautioned that, rather than be indirectly contained in PCAOB standards, guidance for issuers should be developed and released by the SEC.
  • Board member Charlie Niemeier raised concerns about what appears to be a trend of relying on increased disclosures to offset measurement uncertainty, even though disclosures are subjective and difficult to audit.
  • One member wanted to emphasize the importance of professional skepticism on the part of auditors.

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Joint ACCA-Deloitte conferences on 'IFRS in the UK'

25 Oct 2010

The Association of Chartered Certified Accountants (ACCA) and Deloitte are hosting two conferences in November on IFRS for companies in the United Kingdom.

The conferences, entitled 'Choosing your GAAP - IFRS for UK Companies', will discuss the UK Accounting standards Board (ASB) consultation document (issued in late 2009) with respect to introducing the IFRS for SMEs, and the consequent Financial Reporting Exposure Draft (FRED) expected in November 2010. The new accounting framework will affect tens of thousands of companies in the UK.

The locations and dates are as follows:

  • Edinburgh - 16 November 2010, speakers will be Jim Boyle (Deloitte Partner) and Andy Simmonds (Deloitte Partner and ASB board member)
  • Aberdeen - 24 November 2010, speakers Graham Hollis (Deloitte Partner), Chris Hunter (Deloitte Audit Senior Manager) and Christine Couper (Deloitte Tax Manager)

 

CESR summaries of IFRS enforcement decisions

25 Oct 2010

The Committee of European Securities Regulators (CESR) has published its ninth batch of extracts from its confidential database of enforcement decisions taken by EU national enforcers of financial information.

From time to time, CESR publishes extracts of selected decisions as a source of information to foster appropriate and consistent application of IFRSs in the EU. Topics covered in batch #9 of CESR's extracts:
  • Classification of financial liabilities
  • Financial instruments – Hedge accounting
  • Revenue recognition
  • Intangible assets
  • Impairment of non-financial assets
  • Consolidation
  • Share-based payment
  • Financial instruments – disclosures
  • Impairment of non-financial assets — disclosures
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Deloitte comment letter on the IASB's revenue from contracts with customers exposure draft

24 Oct 2010

Deloitte's IFRS Global Office has submitted a letter of comment to the IASB on exposure draft ED/2010/6 Revenue from Contracts with Customers.

The core principle proposed in the ED would require an entity to recognise revenue to depict the transfer of goods or services to customers in an amount that reflects the consideration that it expects to receive in exchange for those goods or services.

Below is an excerpt from the comment letter:

We disagree with certain aspects of the ED's proposals and we have significant concerns over other aspects. Nevertheless, we continue to support the boards in their overall objective of creating a common revenue Standard, and we believe that the work done by the boards to date can, if further developed and modified, form the basis for a clear and robust Standard on revenue recognition.

Our main concern with the ED is that the material in relation to 'control' is neither well developed nor clearly explained. As drafted, the guidance could be interpreted in a number of ways, which could lead to significant diversity in practice. We note that it is particularly unclear how the proposed guidance should be applied to the provision of many services.

We believe the ED's proposals on how the transaction price should be allocated between performance obligations, and on how to account for contract modifications that are judged interdependent, should be modified. As currently drafted, they will sometimes result in accounting that fails to depict properly the economic substance of the underlying arrangements.

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