Deloitte comment letter on EFRAG discussion paper

  • Deloitte Comment Letter Image

26 Aug 2011

Deloitte's IFRS Global Office has submitted a letter of comment to the European Financial Reporting Advisory Group (EFRAG) on its Discussion Paper Considering the Effects of Accounting Standards.

The comment letter highlights Deloitte's views on the contribution the discussion paper has in the methodology for effects analyses development as it relates to the IFRS Foundations Trustees' Strategy Review. The following is an excerpt from the letter:

We agree with the principle that effects analysis should be an element of the standard-setting process throughout the life cycle of a standard-setting project, including post-implementation reviews. We do not think that the same level of detail is necessary at each stage of a project and think that different procedures might be employed at different stages. . . . The methodology employed must be scalable, and the extent of effects analysis must be appropriate to the project in question (i.e., effects analysis should be proportional). Furthermore, we think that the principle of subsidiarity should apply. Consequently, effects analyses should be conducted by the IASB in conjunction with national or regional agencies with an interest in financial reporting.

In addition, we think the EFRAG should 1) collect and assimilate the responses, 2) identify the key findings, and 3) make recommendations to the IFRS Foundation Trustees' Due Process Oversight Committee.

Click to Download our Comment Letter on EFRAG's Discussion Paper Considering the Effects of Accounting Standards (PDF 104k). All of our past comment letters are here.

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