We commend the International Accounting Standards Board for its efforts to improve its deliberative procedures, increase opportunities for consultation and enhance the transparency of its due process. We support the approach outlined in the Draft Handbook and think that it will be a useful document in explaining the approach to standard-setting adopted by the IASB.

However, we are puzzled about what the IASC Foundation Trustees hope to achieve from this exposure. Deloitte Touche Tohmatsu commented on the IASB’s Invitation to Comment Strengthening the IASB’s Deliberative Process in June 2004. Given that there was a broad level of agreement that the proposals were appropriate and that the Board has already implemented the changes, we fail to see the point of inviting comments on the Draft Handbook. This confusion is increased by the lack of any direction in the Invitation to Comment towards those areas on which the Trustees would particularly welcome comments.

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