EBA欧洲银行-2011-02-24-EBA-comments-on-IFRS-F-strategy-review_6页_185kb

EBA Summary of Comments on IFRS Foundation Public Consultation Paper: Status of Trustees' Strategy Review

Core Content

The European Banking Authority (EBA) has provided detailed comments on the IFRS Foundation's public consultation paper regarding the status of the Trustees' Strategy Review. The EBA, established on 1 January 2011, emphasizes the importance of high-quality, transparent, and comparable financial reporting standards for the banking and financial industry, as well as for strengthening market discipline.

Main Views

Mission Statement

• The EBA supports the current mission statement of the IFRS Foundation, which focuses on providing decision-relevant information to investors and other users of financial information.
• However, it believes that financial stability considerations should be given appropriate weight in standard setting.
• To achieve this, the EBA suggests:
  • Wider engagement of financial stability authorities in the standard-setting process.
  • Including an explicit reference to financial stability in the organisation's framework or constitution.
  • Assessing and minimising the impact of new or modified standards on financial stability.

Governance Structure

• The EBA generally supports the current three-tier governance structure (Monitoring Board, Trustees, and IASB).
• It proposes that the most senior tier, responsible for accountability to public authorities, should be a publicly and politically legitimated oversight body.
• The Financial Stability Board (FSB) is suggested as a natural candidate for this role due to its broad representation and political legitimacy.
• The EBA recommends:
  • Extending the Monitoring Board membership to include more voting members from the banking supervision sphere.
  • Ensuring geographical balance and adequate representation of IFRS users.
  • Enhancing the role of the oversight body in agenda setting and strategic orientations.
  • Improving transparency and effectiveness of the Monitoring Board.

Standard-Setting Process

• The EBA supports a more consultative agenda-setting process for the IASB.
• It encourages the use of structured stakeholder engagement, especially before developing Exposure Drafts (EDs).
• The EBA highlights the need for:
  • Clear criteria for re-exposure of EDs.
  • Sufficient resources to address market participants' needs and prepare cost-benefit analyses.
  • A period of calm and stability in accounting standards post-2011 to avoid overloading preparers with new standards.

Financing Mechanism

• The EBA believes that a stable and diversified funding mechanism is essential for the IFRS Foundation to operate effectively.
• It suggests that funding should be non-voluntary for jurisdictions that apply or are converging to IFRS.
• The EBA notes that:
  • Funding should not threaten the independence of the IFRS Foundation.
  • There may be a trade-off between linking governance participation to IFRS adoption and ensuring broad participation.
  • The issue of linking governance participation to a commitment to adopt IFRS requires further consideration.

Key Information

• The EBA does not raise any further issues at this stage.
• The comments are intended to complement, not pre-empt, the views on the proposals from the related public consultation.
• The EBA encourages continued structured dialogue between the IASB and prudential regulators, including the FSB.
• The EBA also recommends the use of field testing and ex-post analyses to evaluate the impact of new standards on financial stability.

Conclusion

The EBA's comments reflect a balanced approach between maintaining the independence of the IFRS Foundation and ensuring that financial stability is adequately considered in the standard-setting process. The EBA supports a more structured and inclusive governance model and emphasizes the importance of transparency, stakeholder engagement, and stable funding for the continued effectiveness of the IFRS Foundation.