August

CFA Institute critiques SEC IFRS report

11 Aug 2012

The Chartered Financial Analysts Institute (CFA Institute) has published a brief summary of issues arising from the staff report of the United States Securities and Exchange Commission (SEC) on the possible incorporation of IFRS into the U.S. financial reporting system. The summary provides a critique of the report, pointing out a number of areas where the CFA Institute believes more analysis and evaluation is required.

The report, entitled Does the SEC have the will to find a way towards IFRS? notes that the final report is "comprehensive and organized" around a number of key themes, such as the costs and obstacles issuers would face in making a change from US GAAP to IFRS and the degree to which existing US GAAP is entrenched in U.S. regulatory regimes.

However, the report opines that "observations on investor preparedness, regulatory impact, issuer impacts, and human capital readiness offer commentary on the current state of affairs which, in our view, will evolve once a decision to adopt IFRS is made".  The report later concludes that in the CFA Institute's view "readers of the Final Report are left with data and observations but without an indication of how they will be weighed and evaluated".  The report laments the lack of analysis of whether IFRS is 'so sufficiently flawed' as not to be interests of investors, what exact modifications to IFRS would be needed to incorporate it into the US reporting regime, and whether issues of lack of comparability in IFRS is a greater obstacle than exists with multiple accounting languages.

The report outlines a number of analytical or evaluative questions that the SEC staff report does not answer, such as:

  • Which of the dimensions of the SEC IFRS Work Plan are most critical to a recommendation?
  • Which, if any, of the challenges are considered to be insurmountable and why?
  • What, if any, actions can or should be taken (and by whom) to address the challenges or obstacles, and over what time period?
  • To what degree should 'regulatory capture' of U.S. GAAP serve as an obstacle or deterrent to adopting accounting standards which are meant to serve investors rather than regulators?

The report concludes with the following observation:

Requiring most immediate attention, the Final Report leaves stakeholders wondering: What are the SEC’s next steps? Will there be a recommendation and what might be its timing? We believe it is imperative for the SEC to define the way forward, as failure to act or provide clear direction is, in substance, a decision not to incorporate IFRS. Rather than continued evaluation and delay, we believe investors would prefer the SEC to provide a path forward with an affirmative or negative decision.

Click for access to the CFA Institute report (link to CFA Institute website).

Additional resources related to the SEC report:

Indian minister suggests IFRS adoption from 2013

10 Aug 2012

In a speech given in New Delhi at a seminar organised by The Associated Chambers of Commerce and Industry of India (ASSOCHAM), the Indian Minister for Corporate Affairs and Power, Dr. M. Verappa Moily, has indicated that the implementation of Indian Accounting Standards that are compatible with International Financial Reporting Standards (IFRS) may occur by April 1, 2013.

In February 2011, the Indian Ministry of Corporate Affairs (MCA) issued 35 Indian Accounting Standards (Ind AS) that are converged with, but not identical to, International Financial Reporting Standards (IFRS).  A that time, it was announced that a 'phased implementation' would only proceed once certain Indian tax and other issues were resolved.

The tax issues revolve around the Indian Direct Taxes Code (DTC), in relation to the use of accounting information in determining tax liabilities.  There have no substantive developments on the DTC to date comprehensively addressing these issues and accordingly, no timetable for the implementation of Ind AS has been announced.

However, Dr Moily noted the following in his speech:

We have taken the initiative that irrespective of whenever the DTC comes we will take it up with the Ministry of Finance and we are determined to ensure that IFRS is implemented by April 1, 2013

The comments were made in the context of a discussion about "reforms in the processes of doing business in India [that] are vital to keep pace with changing times and global trends".  Whilst the speech is not definitive, and India's IFRS implementation is subject to further due process, this development may indicate an increased likelihood of India eventually moving to IFRSs.

Click for press release (link to ASSOCHAM website).


ACCA research report discusses effects of integrated reporting

08 Aug 2012

A report from the Association of Chartered Certified Accountants (ACCA) provides insights into the impact of integrated reporting on companies' corporate reporting, based on an academic study of recent experience in South Africa. The ACCA report contains a number of specific recommendations that could be taken into account by those developing the international integrated reporting framework, under the auspices of the International Integrated Reporting Council (IIRC), or otherwise.

The ACCA's report, presented as a discussion paper entitled Reporting pre- and post-King III: what’s the difference?, summarises the findings of a full academic report called Integrated reporting: the new face of social, ethical and environmental reporting in South Africa? written for the ACCA by Jill Solomon (King’s College London) and Warren Maroun (University of the Witwatersrand, Johannesburg).

Integrated reporting has been mandatory for entities listed on the Johannesburg Stock Exchange in South Africa since 2010-11.  The research analysed the corporate reports of ten major South African companies, including a number of resources companies,  immediately before (2009) and after (2010–11) the introduction of mandatory integrated reporting.

Some of the findings of the research included:

  • Integrated reporting sees significantly more social, environmental and ethical information included in corporate reports, and in more places throughout the report - although this sometimes leads to repetition which is seen as a significant weakness
  • The impact of integrated reporting on the way that social, environmental and ethical information is disclosed can be characterised by the following themes: the crucial importance of materiality; an evolving discourse of risk and risk management; an increasing tendency towards quantification; the emergence of new reporting items; the emergence of new sections in the reports; and the increasing integration of social, environmental and ethical considerations into corporate governance structures
  • Companies have shifted from reporting that is aimed exclusively at their shareholders to reporting that expounds the directors’ claimed belief in stakeholder accountability and stakeholder engagement.

ACCA’s analysis offers five recommendations for the development of integrated reporting, based on the academic’s findings:

  1. The way in which information is set out could be more concise to avoid repetition
  2. The form of reporting could be extended to incorporate more feedback from consultation with stakeholders regarding social and environmental issues and corporate responsiveness to feedback
  3. Organisations should solicit the views of their major stakeholders about the social, environmental and ethical information (and underlying policies and practices) that they report and include these views within integrated reports
  4. Academics can and should play a significant role in researching the integrated reporting framework and its applicability
  5. Academics should, can and do play an important role in educating potential managers and users in integrated reporting through university and professional education in which they are involved.

Click for more information (link to ACCA website).

IFRS Foundation publishes Formula Linkbase 2012

07 Aug 2012

The IFRS Formula Linkbase 2012 is now available for download on the IASB's website. The formula linkbase was developed to (1) improve the data quality of IFRS taxonomy filings and (2) provide additional guidance to better understand the IFRS concepts and their meaning from a financial reporting and a technical perspective. This version of the formula linkbase is updated from the formula prototype released in October 2011. The 2012 formulae are designed to work with the IFRS Taxonomy 2012. Most of the improvements from the previous version are related to the content.

The formula linkbase can be used with software packages supporting the XBRL formula specification 1.0 and allows for additional validations of the reported facts. Developed in a generic manner, the IFRS Formula Linkbase 2012 can be used directly on the filings created, based on the IFRS Taxonomy (instance documents) or the company specific extensions to the IFRS Taxonomy (filer extension taxonomy and instance document). Guidance documentation for the formula linkbase is also available.

Technical changes in the 2012 version include (1) positive and negative formula validation is placed in separate files, (2) redundant members in the filter for the Dimension aggregation formulae are removed and (3) precondition expressions in the validation are  simplified (earnings per share formulae).

Click for the press release to access the Formula Linkbase 2012 on the IASB's website.

New research on the value of 'extra-financial' disclosure to investors and analysts

06 Aug 2012

A new research report has been issued exploring how investors and analysts source, use and are influenced by so-called 'extra-financial information', which includes Environmental, Social and Governance (ESG) information and other non-financial information. The report shows that for the majority of investors and analysts surveyed, extra-financial information is very relevant or relevant to investment decision‑making or analysis.

The report, entitled The value of extra-financial disclosure - What investors and analysts said is the result of a survey commissioned by the Global Reporting Initiative (GRI) and The Prince’s Accounting for Sustainability Project (A4S), and conducted by Radley Yeldar.  The survey involved a relatively small sample of investors and analysts but is considered "a useful snapshot of investor and analyst sentiment towards extra-financial disclosure at the present time".

Some of the findings from the survey included:

  • Over 80% of the research sample believe that extra-financial information is very relevant or relevant to their investment decision‑making or analysis
  • Investors and analysts use multiple sources to gather relevant financial and extra-financial information but show a strong preference for sources which are more comprehensive and specialised - with direct engagement with Board level representatives, followed by formal reporting channels such as the sustainability report, annual report or integrated report are most influential
  • Over 80% of investors and analysts surveyed  believe that integrated reporting will deliver benefits to their analysis and company assessments - seeing integrated reporting as useful or very useful for increasing the reliability, accessibility, relevance and comparability of extra-financial information, as well as improving assessments of future company performance
  • A majority of respondents were not familiar with eXtensible Business Reporting Language (XBRL), with less than 10% of those surveyed indicating they use XBRL and that it affects how they receive financial information.

Click for more information (link to GRI website).

Summary of the July 2012 Trustees’ meeting

02 Aug 2012

The IASB has posted to its website a summary of meeting of the Trustees of the IFRS Foundation that took place in Washington on 12 July 2012.

The Trustees of the IFRS Foundation, the body responsible for the governance and oversight of the International Accounting Standards Board (IASB), discussed the following topics:

  • Report of the Chairman of the IASB concerning the four main Memorandum of Understanding (MoU) and convergence projects as well as the progress the IASB was making in determining its future agenda.
  • Report of the Chairman of the IFRS Advisory Council on the issues discussed at the June 2012 meeting of the Council and the draft Due Process Handbook.
  • Report of the Chairman of the Due Process Oversight Committee on initial feedback received on the draft Due Process Handbook, which is being exposed for public comment, and on the comprehensive review of the IFRS for SMEs.
  • Update on the IFRS for SMEs
  • Regional outreach activity on whether and how to incorporate IFRSs into the US financial reporting regime.
  • Meeting with the IFRS Foundation Monitoring Board regarding the progress made in following up the recommendations of their respective reviews of the governance and strategy of the organisation.

Please click for the full summary on the IASB's website. The next meeting of the Trustees of the IFRS Foundation is scheduled for 12 October 2012.

You can also access the preliminary and unofficial notes taken by Deloitte observers for this meeting.

IVSC calls for views on valuation of trade related property

02 Aug 2012

The International Valuation Standards Council (IVSC) has released a discussion paper on the valuation of trade related property, which includes buildings or other structures that are purpose built for a specific type of business activity. Examples of trade related property include hotels, theatres and fuel stations, together with others such as bars, restaurants, casinos, clubs, and healthcare properties.

The IVSC had previously issued a Guidance Note, GN 12 The Valuation of Trade Related Property and had issued an exposure draft which proposed to update and reissue the guidance as part of its revamped valuation standards, which were ultimately issued in July 2011.

However,  the IVSC chose not to finalise the valuation standard on this topic because there were questions whether sufficient guidance on trade related property was already included in other valuation standards, a perceived confusion of a real property interest with a business, and the need to consider the need for specific valuation guidance of this type.

The discussion paper seeks constituent input as to whether it is practical and necessary to define a distinct category of real property for valuation purposes based on the degree to which the buildings or any other structures are specialised, and explores various issues in undertaking such a valuation.

The IVSC is seeking comments on the Discussion Paper by 31 October 2012.  Click for:

FASB seeks input on private company decision-making framework

01 Aug 2012

The United States Financial Accounting Standards Board (FASB) issued an Invitation to Comment on a staff paper outlining an approach for deciding whether and in what circumstances to modify US GAAP for private companies. In its paper, 'Private Company Decision-Making Framework: A Framework for Evaluating Financial Accounting and Reporting Guidance for Private Companies', the FASB recommends criteria for determining when it is appropriate to adjust financial reporting requirements for private companies. The goals of the decision-making framework are (1) to help the FASB and the newly-created Private Company Council (PCC) identify the needs of private company financial statements users and (2) to create opportunities that reduce the complexity and cost of preparing private company financial statements in accordance with US GAAP.

Before it is implemented, the proposed decision-making framework must be agreed upon by both the FASB and the PCC. As reported earlier, the PCC was established by the Financial Accounting Foundation (FAF) to to improve the process of setting accounting standards for private companies following US GAAP. Working with the FASB, and guided by the framework, the PCC will determine whether exceptions or modifications to existing non-governmental US GAAP are necessary to address the needs of users of private company financial statements. The PCC will then identify, deliberate, and vote on any proposed changes. These changes will be subject to endorsement by the FASB and then submitted for public comment before they can be incorporated into GAAP.

The recommendations contained in the Invitation to Comment reflect what stakeholders told the FASB staff about their experiences using, preparing, auditing, reviewing, and compiling private company financial statements. The staff identified six significant factors that differentiate private companies' financial reporting considerations: types and number of financial statement users, access to management, investment strategies, ownership and capital structures, accounting resources, and learning about new financial reporting guidance.

The Invitation to Comment also seeks feedback on five areas where financial accounting and reporting guidance might differ for private and public companies: recognition and measurement, disclosures, display (presentation), effective dates and transition methods.

The Board will not deliberate the topics in the Invitation to Comment until after it has received stakeholders' input on the preliminary recommendations and all members of the PCC have been appointed. The FASB and PCC will then jointly reach tentative conclusions about the criteria to be included in the framework.

Feedback on the FASB's Invitation to Comment is due by 31 October 2012.

Please click for:

  • The press release to access the Invitation to Comment on the FASB's website.
  • Deloitte (United States) Heads Up newsletter on the private-company decision-making framework discussion paper.
  • FASB webcast on the private company decision-making framework project, held on 14 September 2012.

Stay Tuned Online – IFRS and UK GAAP update

01 Aug 2012

The Deloitte London IFRS Centre of Excellence is running a series of hour-long Internet-based financial reporting updates, aimed at helping finance teams keep up to speed with IFRSs and other financial reporting issues.

Each update lasts no more than an hour, and sessions are normally held three times a year, approximately at the end of March, July, and November. We intend to make a recording of each session available on IAS Plus for a period of at least four months from the date of the presentation.

The following topics were covered in the July 2012 webcast:

  • Latest IFRS developments
  • Other UK reporting developments
  • Eurozone uncertainties
  • The future for financial instruments

To access the recording click here.

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