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Our views on Conceptual Framework discussion paper

21 Nov 2006

We have submitted to the IASB Our Comments on the Discussion Paper (DP): Conceptual Framework–Objective and Qualitative Characteristics.

Although we agree with many of the provisions in the proposed framework, we have concerns about some of them, including the following:
  • Insufficient emphasis is given to stewardship as an objective of financial reporting. Our letter states:

    "Management, in addition to having the responsibility for allocation of the assets entrusted to it for the benefit of shareholders, also has an obligation to provide its shareholders with an account of what it has done with those assets. This account has to be a faithful and complete historic description of the entity's assets and liabilities at the beginning and end of the accounting period, coupled with management's explanation of how those balances changed during the period. Recognizing this broader meaning of 'stewardship' as one of the primary objectives of financial reporting both supports all of the qualitative characteristics of financial reporting information proposed in the DP, and helps to align management's behaviour with the objectives of all of the entity's stakeholders. Such a stewardship objective will emphasize the role of financial reporting as a dialogue between management and the owners of the business."

  • While present and potential investors and creditors view cash flow information as essential for their decision-making, they also value other information not specifically tied to cash flows. For example, many non-cash transactions such as asset write-downs and share-based payments lend insight into management's stewardship and the impact of current economic factors on the entity's assets and liabilities. Other information such as sensitivity or trend analyses might prove equally useful;
  • Different information needs of different categories of users of financial reports should be set out in a hierarchy;
  • The DP focuses on financial reporting, rather than financial statements, but does not define financial reporting;
  • Reliability should be regarded as an essential attribute of financial information and as an additional and separate characteristic that should not be subsumed in the attributes of faithful representation and verifiability
  • 'Substance over form' should be identified as a component of representational faithfulness,
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Proposed revisions to 'cost approach' valuation guidance

21 Nov 2006

The International Valuation Standards Committee has published Proposed Revisions to International Valuation Guidance Note 8 – The Cost Approach for Financial Reporting.

The proposed revisions are the result of requests for clarification and suggestions of minor improvements to the 2005 version of GN8. Comment deadline is 31 December 2006. The IVSC has also released an update of its work programme:

IVSC Work Programme

Eighth edition International Valuation Standards

To be published Q2 2007

Revised IVS 2 - Valuation Bases other than Market Value

Early publication on website Q1 2007

Revised IVA 2 - Valuation for Lending Purposes

Early publication on website Q1 2007

New IVA 3 - Valuation for Financial Reporting of Public Sector Assets

Early publication on website Q2 2007

New GN - Valuation of Historic Property

Early publication on website Q1 2007

Proposed Revisions to GN 8 - The Cost Approach for Financial Reporting

Consultation draft issued Nov 06

Proposed Revisions to GN 9 - Discounted Cash Flow Analysis

Consultation draft to be issued Q1 2007

The Valuation of Intangible Assets for IFRS Reporting Purposes

Exposure draft to be issued Q2 2007

Click for Full Report (PDF 193k).
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IAASB issues three exposure drafts

20 Nov 2006

The International Auditing and Assurance Standards Board (IAASB), an independent standard-setting board under the auspices of the International Federation of Accountants (IFAC), has issued three exposure drafts of proposed International Standards on Auditing (ISAs) that follow its new clarity drafting conventions.

Key elements of those drafting conventions include basing the standards on objectives, as opposed to procedural considerations; using the word 'shall' to identify requirements that the professional accountant is expected to follow in the vast majority of engagements; eliminating the present tense to describe actions by the professional accountant; and structural improvements to enhance the overall readability and understandability of the standards. The three new EDs are:
  • ISA 320 (Revised and Redrafted), Materiality in Planning and Performing an Audit;
  • ISA 450 (Redrafted), Evaluation of Misstatements Identified during the Audit; and
  • ISA 260 (Revised and Redrafted), Communication with Those Charged with Governance.
Comment deadline is 15 February 2007. The exposure drafts may be viewed by going to www.ifac.org/EDs. The EDs remain posted until the final ISAs have been issued.
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New EU procedure for endorsing IFRSs

20 Nov 2006

A new step has been added to the procedure for endorsing IFRSs (including Interpretations) for use in Europe.

The European Commission will be required to submit its endorsement proposals to a Committee of the European Parliament, known as the Regulatory Procedure with Scrutiny Committee. That Committee will give its opinion on endorsement to the Commission within a time frame determined on a case by case basis. If the Committee agrees with the Commission's recommendation, the recommendation goes to the European Parliament and Council for approval, as at present. If, however, the Committee does not agree with the Commission's recommendation, the matter will go directly to the Council. If the Council supports the Commission's recommendation, the matter will go to Parliament for action. If the Council does not support the Commission's recommendation, the Commission will be asked to reconsider the matter and submit a new recommendation. Click for:
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SEC 2006 annual report references to IFRSs

20 Nov 2006

The Performance and Accountability Report of the US Securities and Exchange Commission for the year ended 30 September 2006 makes a number of references to IFRSs including the following progress report under the heading 'Improving Disclosure for Investors':

Global accounting standards. Last year, the SEC staff published a 'roadmap' of the milestones necessary to permit foreign private issuers to file financial statements prepared under International Financial Reporting Standards (IFRS), without reconciling them to U.S. generally accepted accounting principles. The roadmap involves, among other things, a detailed analysis of the faithfulness and consistency of the application, interpretation, and enforcement of IFRS in financial statements across companies and jurisdictions, and continued progress in the convergence work now being conducted by the International Accounting Standards Board and the Financial Accounting Standards Board. The SEC staff has been working with other regulators, including through IOSCO and the Committee of European Securities Regulators (CESR), to help reach some of these milestones. For example, the SEC staff and CESR finalized a work plan in 2006 to share information about IFRS implementation.
Click for Full Report (PDF 2,294k).
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Board agenda project pages updated

19 Nov 2006

We have updated the following agenda project pages to reflect the discussions and decisions at the International Accounting Standards Board's November 2006 meeting:

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EITF Snapshot for November 2006

18 Nov 2006

We have posted the latest edition of EITF Snapshot summarising the 16 November 2006 meeting of FASB's Emerging Issues Task Force.

EITF Snapshot, published by Deloitte & Touche LLP (USA), enables readers to identify relevant topics and to understand quickly the meeting's outcome. A related newsletter – EITF Roundup – is published immediately after the FASB's consideration of the tentative conclusions and consensuses reached, provides more in-depth information on each of the issues. Click for Snapshot (PDF 96k). Past issues of both of these publications can be downloaded Here.
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Notes from the November 2006 IASB meeting

18 Nov 2006

The International Accounting Standards Board held its November 2006 Board meeting at its offices, 30 Cannon Street, London, on Thursday 16 November 2006 and Friday 17 November 2006.

Click here to go to the Preliminary and Unofficial Notes of the November 2006 IASB Meeting taken by Deloitte observers.

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European discussion paper on the conceptual framework

17 Nov 2006

The European Financial Reporting Advisory Group (EFRAG) and the French accounting standard setter (Conseil National de la Comptabilite, or CNC) have jointly published the first Discussion Paper under the auspices of the Pro-active Accounting Activities in Europe (PAAinE).

The Discussion Paper is titled The Conceptual Framework: Starting from the Right Place? It elaborates on the following issues:
  • Purpose of the conceptual framework
  • Users of financial reporting
  • Entities within the scope of the Framework
  • The scope of financial reporting.
EFRAG and CNC invite comments, which are due by 18 March 2007. Click to Download the Discussion Paper PDF 873k).

 

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Final notes from the World Congress of Accountants

17 Nov 2006

The World Congress of Accountants in Istanbul, Turkey, held its last session on 16 November 2006. Over 5,000 delegates from 120 countries attended the four-day meeting.

Presented below are notes from a number of the sessions on the fourth and final day of the Congress.

Notes from the XVII World Congress of Accountants

Istanbul, Turkey, 16 November 2006

Workshop: Emergence of the accounting profession in the CIS countries

Ndung'u Gathinji (CEO, ECSAFA, Kenya) chaired a session dedicated to examining how accountants in the Commonwealth of Independent States are coping with the transition from a managed demand economy to a market economy.

Frederic Gielen (UK Financial Reporting Council, on loan from the World Bank) noted that a comprehensive reform of the financial system in the CIS was needed when the region embraced the market economy in the early 1990s. He said that the World Bank recognised the link between sound financial reporting and poverty reduction and was an advocate for improved standards and compliance. Fundamental to this was the Bank's Report on Systems and Codes (ROSC) programme. Under the ROSC approach, the accounting profession is a key pillar in a stable financial architecture. ROSC assessments had been completed in five of the CIS countries and noted that progress was very encouraging although there were areas for improvement-not least in the compensation of accounting academics.

Igor Kozyrev (Deputy Chief Accountant, Lukoil, Russia) spoke of the changing and developing nature of the accounting profession in Russia, in particular the demand placed on it by moving from a managed to a market economy. He noted that under the Soviet system, accountants were part of a compliance network and were often involved in forensic investigations. The transition to a market economy was difficult because there was a lack of experience-both technical and psychological-in the use of judgement (rather than following state-dictated regulations). He noted that accounting reform in Russia had improved the quality of financial information but had also improved the quality of company management and the use of resources.

Prof Adolf Enthoven (University of Texas, USA) gave an overview of the history of the accounting profession in Russia, noting that prior to 1917 its history followed that of the profession in Europe. The 1917 Revolution had meant that the purposes of accounting had changed-accountants now served the State's central planning purposes, and served them well. He noted several challenges facing the profession-not least the lack of an official status for IFRS-based financial reporting and a formalist approach by regulating authorities. However, he observed that this was changing and that by 2010 significant reforms are expected to be in place.

Rick Gurley (US AID, Ukraine) gave an account of US AID's involvement in the development of a recognised accounting curriculum and qualification in the CIS. Based on knowledge of IFRS and ISA, the IFAC Code of Ethics and similar globally recognised foundations and working with CGA Canada, the Certified International Professional Accountant qualification had been developed. The CIPA exam is administered and marked by an independent body under the auspices of IFAC, US AID and the Eurasia Council of Certified Auditors and Accountants (ECCAA), a regional body recognised by IFAC. The CIPA exam has been very successful in the region and there is hope that it can be rolled out in other regions.

Plenary Session 3

The topic of this session was value creation through professional accountants in business.

Graham Ward (out-going President of IFAC, UK) opened the session by noting that IFAC had devoted significant resources in the past two years to highlighting the role of the professional accountant in business, noting that (because of their training) professional accountants bring a critical set of skills to businesses and use those skills to add value.

Lady Barbara Judge (Deputy Chair, Financial Reporting Council, UK) is not an accountant-she is a lawyer by training and a former Commissioner of the US Securities and Exchange Commission. She spoke from personal experience as a company director of the value of having a professional accountant – one who is a member of a body regulated by the IFAC codes of conduct and ethics – on the board of a publicly-accountable company.

She noted that today's world is about numbers and real-time reporting. The professional accountant can 'feel and see' what is wrong and ask the right questions to identify problems quickly. Boards of directors need this expertise, especially in the chair of the audit committee who, she said, should always be a professional accountant. The board is also responsible for governance and ethics-something that professional accountants bring with them as members of IFAC member bodies. The board is also responsible for enterprise strategy and professional accountants can help their board colleagues to focus on strategy and strategic risk assessments.

She concluded her remarks by reminding the audience that the board was also responsible for internal controls and that professional accountants can help their colleagues to understand these. Their expertise was something that helped her, as the chairman of one company and a director of others 'to sleep at night in a Sarbanes-Oxley environment'.

David Hastings (Shell Canada Limited, Canada) focused on how professional accountants in business create value for the business in which they work: identifying where, how and why value is created.

The professional accountant is central to identifying value drivers in today's economy: innovation, customer satisfaction, the war for talent, the effects of technology and brand investment. They have an holistic view of the business, putting customers first while understanding all dimensions of the business and managing risk effectively. As such, they can assimilate both the financial and non-financial information that is needed across a business. Value is created through the professional accountant's ability to identify and manage risk; to think and act globally and to recognise the difficulties and opportunities in a global economy.

Mary Keegan (HM Treasury, UK) spoke of the role of the professional accountant in creating value for citizens. In central government, there can be no second best. It was incumbent on government to improve the delivery performance to its citizens and to improve the financial management of the delivery of public services. She noted that the UK government uses a Value for Money model-concentrating on Economy, Efficiency and Effectiveness-and looks as much at the future value drivers as it does on historical data.

Central to this strategy is having the right systems delivering the appropriate data quickly; using this information to drive performance; and implementing good governance and proper management structures throughout the government supply chain. Ms Keegan noted that the UK has put in place a requirement that all government departments have an audit committee of non-executive members and that all government boards must have a professional accountant (a member of an IFAC member body) as finance director.

She noted that governments should govern by numbers not by instinct and consequently, accountants are properly placed at the centre of policy formulation and service delivery. She concluded her remarks by saying that governments had a responsibility to deliver value to their citizens and that there is a vital role for the professional accountant. Consequently, professional accountants must be at the policy table.

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