EBA欧洲银行-2006-2009-2022-20-20-28CEBS-20-20CL-20Draft-20IFRI_4页_148kb

CEBS Comments on IASC Foundation Draft Due Process Handbook for the IFRIC

Core Content

The Committee of European Banking Supervisors (CEBS) has provided feedback on the Draft Due Process Handbook for the IFRIC, issued by the IASC Foundation. CEBS supports the publication of the handbook and acknowledges its efforts to address previous concerns, particularly those raised in the "Review of Constitution: Proposals for Change" (2004) and the "Review of IFRIC Operations: Consultative Document" (2005). The main focus of CEBS's comments is on enhancing the transparency, consistency, and coherence of the IFRIC interpretative process, especially in a principles-based regulatory environment.

Main Points and Concerns

1. Role and Timeliness of IFRIC Interpretations

• CEBS appreciates the effort to improve the interpretative process but emphasizes that adequate and timely interpretation is crucial for the smooth implementation of IFRS.
• They believe that the IFRIC should maintain a balance between due process and responsiveness to urgent issues.
• CEBS supports the idea of the European roundtable on IFRS application as a potential mechanism for addressing urgent matters, but encourages IFRIC to continue its work to enhance the interpretative process.
• They also support the liaison relationships with national standard setters and interpretative bodies, provided the workflow remains homogeneous and coherent.

2. Principles-Based Nature of IFRS

• CEBS supports the principles-based nature of IFRS, which allows for flexibility in interpretation.
• However, they warn that decisions on the IFRIC agenda may have de facto interpretative force, and thus the working procedures of IFRIC should be transparent.
• They suggest that more detailed transparency should be ensured, especially regarding the agenda selection process and the wordings of rejections.
• CEBS recommends that the current draft be further improved in terms of procedural clarity and transparency.

3. Retrospective Application of IFRIC Interpretations

• CEBS acknowledges the retrospective application of IFRIC interpretations as consistent with IAS 8.
• However, they are concerned about the potential for increased restatements in financial statements due to this approach.
• They recommend that cost/benefit analyses be included in the decision-making process for retrospective application.
• CEBS also highlights the consequences of issuing a wording for rejection, which may have similar effects to an interpretation and should be treated with the same care.

4. Agenda Committee and Agenda Criteria

• CEBS supports the consultative process for issues not added to the IFRIC agenda.
• They suggest that the Agenda Committee should publicly share significant working papers to improve transparency.
• CEBS recommends that the current agenda criteria, particularly 28-f, should be revised to ensure that issues requiring interpretation are not excluded solely based on the expected timeline of IASB projects.
• They propose that the absence of consensus should only be acknowledged after a debate among participants, rather than assumed.
• CEBS also suggests that the last sentence of paragraph 31 should be revised from "The IFRIC may recommend..." to "The IFRIC recommends..." to ensure a more formal and binding recommendation.

Key Recommendations

• Public availability of Agenda Committee working papers.
• Clarification of the definition of "national interpretative groups" (NIGs).
• Revised agenda criteria to ensure that all necessary interpretative issues are addressed, regardless of the IASB project timeline.
• Enhanced transparency in the agenda selection and interpretative decisions.
• Inclusion of cost/benefit analyses when deciding on retrospective application.
• Systematic referral of unresolved issues to the IASB for possible standard modification.

Conclusion

CEBS encourages the IFRIC to maintain a consistent and transparent interpretative process, while also ensuring timeliness and responsiveness to issues affecting the banking and financial sector. They believe that clarity in definitions and procedures is essential to support the consistent application of IFRS and to strengthen market discipline.