New York City, Public Portion, Afternoon of 31 October 2007 (13:15-17:00pm)

• Approval of July Minutes
• Report of the Procedures Committee
  • Feedback from September meeting with IASB
  • Discussion of IASB consultation initiatives
  • Feedback statements
  • Cost benefit analyses
  • New Committee name
• Report of the IASB Chairman
  • Review of convergence activities (United States, Japan, China, and India)
  • 2008 goals
  • Discussion of Proposed Agenda Items
  • Discussion of any implications of sub-prime and liquidity crisis for IFRSs
• Update on long-term funding

The International Accounting Standards Board and the U.S. Financial Accounting Standards Board have for years been working on a convergence project to eliminate needless regulatory friction between International Financial Reporting Standards and U.S. Generally Accepted Accounting Principles. And that has made possible the SEC's announcement that we are taking the next steps on our Roadmap to eliminate the reconciliation requirement in the United States, and that we are even considering allowing U.S. issuers to use IFRS....

IFRS promises to integrate our markets. But that promise is jeopardized if IFRS isn't applied faithfully and consistently across jurisdictions. Regulators must beware the impulse to develop nationally-tailored versions of IFRS, and we must cooperate with one another in implementing a set of standards that is faithfully and consistently applied.

Since 2005, the SEC has been following a publicly announced 'Roadmap' that charts a path to when issuers would no longer be required to reconcile their IFRS financials statements to U.S. GAAP. We're well down the path charted in the 'Roadmap', and we're still very much on track to eliminating the reconciliation requirement by 2009.

Whilst we support the IFRIC's efforts to provide clarification for transactions in which agreements for sale of real estate are reached before the construction is complete, we do not support the consensus as proposed in the Draft Interpretation as it does not clearly articulate the underlying principles and logic to distinguish a contract for the delivery of goods from that for the delivery of construction services. To assist the IFRIC in their re-deliberations of the Draft Interpretation we have articulated what we see as the relevant principles in Appendix A to this letter. The Appendix suggests some indicators to assist in distinguishing the characteristics of the delivery of goods from those of construction services. In our view, whether a contract is for the delivery of goods or for the provision of construction services is a spectrum in which judgement will need to be exercised in order to determine how a contract should be classified.