EBA欧洲银行-2006-11-0328CEBS-CL-DP-Conceptual-Framework29_5页_149kb

CEBS Summary of Discussion Paper on Improved Conceptual Framework for Financial Reporting

Core Content

The Committee of European Banking Supervisors (CEBS) has provided detailed comments on the Discussion Paper published by the International Accounting Standards Board (IASB) and the Financial Accounting Standards Board (FASB), which outlines Preliminary Views on an improved Conceptual Framework for Financial Reporting. The paper focuses on two main areas: the Objective of Financial Reporting (OB) and the Qualitative Characteristics of Decision-useful Financial Reporting Information (QC).

CEBS views the conceptual framework project as a key step in achieving international convergence of accounting standards and in developing principles-based, high-quality standards. However, they believe that some of the conclusions in the paper require further discussion, especially in terms of authoritative status, stewardship assessment, and qualitative characteristics.

Main Views and Key Concerns

1. Authoritative Status of the Framework

• CEBS encourages the IASB to foster further debate with the FASB on the authoritative status of the conceptual framework.
• They believe that the authoritative status is a fundamental aspect of the project and should be addressed promptly to ensure consistent application.
• CEBS prefers a principles-based framework with a high authoritative status, at least equivalent to the current status of IAS 8.
• They suggest the introduction of a "comply or explain" mechanism to ensure that future standards are consistent with the framework, with exceptions clearly justified.

2. Separate Objective of Stewardship Assessment

• CEBS believes that the assessment of management's stewardship should be a separate objective of financial reporting.
• This is important for banking supervisors and banks assessing the financial health of their counterparties.
• They argue that stewardship is a key aspect of financial reporting for corporate governance and decision-making.

3. Terminology and Scope of Financial Reporting

• CEBS is concerned about the diffuse nature of the Discussion Paper, especially regarding the definition of financial reporting.
• They recommend that the legal implications of replacing financial statements with financial reporting should be carefully considered.
• The boundary of financial reporting is not clearly defined, which could impact regulatory requirements and audit practices.
• CEBS also requests clarification on the change of terminology from "claims" and "resources" to more general terms.

4. Qualitative Characteristics

• CEBS supports the replacement of reliability with faithful representation, but raises concerns about its clarity and international acceptance.
• They believe that faithful representation may not fully capture the importance of professional judgment, especially in illiquid markets.
• CEBS recommends reinforcing the definition of verifiability, aligning with AV2.1 and AV2.2.
• They suggest an explicit statement to maintain balance between relevance and faithful representation.
• CEBS emphasizes the importance of predictive value and confirmatory value, with the latter being linked to stewardship assessment.
• They argue that substance over form should be retained as a distinct qualitative characteristic.

Conclusion

CEBS recommends that the IASB should consider the legal implications of the terminology change, maintain a clear and authoritative framework, and retain key qualitative characteristics such as substance over form and stewardship assessment. They also support the new definition of users and primary users in the preliminary views of OB.

CEBS will continue to monitor the development of the project and is open to further contributions to the ongoing discussion.