REPORTING WITH DIFFERENTIAL FOR SMALL BUSINESS ENTERPRISES Yu Jia, 202724318 ADMS 4510 M, Winter 2002 Differential Reporting, Hargitai ADMS 4510 Winter 2002: 202724318, Yu Jia. Table of Content Abstract ........................................................................................................................................................ 2 Introduction ................................................................................................................................................. 3 The Opinions on Small Business Reporting ...................................................................................... 5 Big GAAP vs. Little GAAP ...................................................................................................................... 5 GAAP is GAAP ......................................................................................................................................... 5 The Users ..................................................................................................................................................... 6 The Users and their Needs .................................................................................................................... 6 Information Asymmetry Theory .............................................................................................................. 9 Foreign Practices......................................................................................................................................11 UK .............................................................................................................................................................11 Australia ...................................................................................................................................................13 New Zealand ...........................................................................................................................................14 US .............................................................................................................................................................15 International .............................................................................................................................................15 Size Issue ....................................................................................................................................................16 Recent Developments in Canada .........................................................................................................17 Background ..............................................................................................................................................17 The Exposure Draft ................................................................................................................................19 The Differential Reporting Framework .................................................................................................20 Eligible Entities and Size Issues .......................................................................................................20 Options .................................................................................................................................................21 Trade-off and Professional Judgment ................................................................................................22 Summary and Conclusion ......................................................................................................................24 1 ADMS 4510 Winter 2002: 202724318, Yu Jia. Abstract The objective of this paper is to review the arguments and reasoning behind my conviction that financial reporting for small business enterprises (SBEs) should be allowed with differential within GAAP. It is my firm opinion that it is the needs of financial information users that determine the contents of accounting standards. To support this position, users and their requirements for small business financial information are both identified and examined. Foreign practices on this topic are reviewed and the enterprise size issue is discussed in relation to the needs of users. The recent developments in small business reporting in Canada and the CICA Differential Reporting Exposure Draft are studied in light of how well they fulfill the objective of accounting information - to meet the needs of users - as defined in the CICA Handbook. My conclusion is that reporting with differential should be permitted within GAAP for small business. It is based on the nature and requirements of the users of SBEs statements with due consideration for professional judgment and tradeoffs. 2 ADMS 4510 Winter 2002: 202724318, Yu Jia. Introduction Currently, Canadian General Accepted Accounting Principles (GAAP) generally applies to all profit-oriented enterprises. As a result, such enterprises are governed by nearly identical financial reporting requirements regardless of their size or the public interest in them. In recent years, due to the globalization of financial markets and the concerns of securities regulators, accounting standards has evolved and developed as justified for public companies on the grounds of public interest. These standards require tremendous disclosure development. Thus, the need to apply the same financial reporting standards to all profitoriented enterprises, including non-public and small, medium size companies, has become more and more an increasing source of debatable. More and more people have questioned whether GAAP continues to be appropriate for nonpublic, small/medium size companies, whose users are limited to a few users. “The imposition of uniform recognition, measurement, and disclosure standards on all entities without adequate consideration of the unique needs of different type of entities and financial-statement users, and the costs and related benefits of alternative approaches to meeting those needs…”i (American Institute of Certified Public Accountants, August 1996, p.1.) This has resulted in the so-called ‘Standards Overload’. It was in this context that the notion of differential reporting or small business accounting has merged. In this paper, I will, first, discuss why there is a need for small business enterprises (SBEs) financial reporting with differential under GAAP. I will present the current opinions on this issue and point out my opinion that information needs 3 ADMS 4510 Winter 2002: 202724318, Yu Jia. of financial-statement users determine the content of accounting standards and thus, reporting should be allowed to reflect appropriate differences. To support this opinion, I will identify the users of the small business enterprises (SBEs) and their needs for SBEs’ financial information from both the users’ point of view and theoretical point of view. I will, second, review the ways in which foreign standard-setters have responded to the challenges the small business information needs pose to general-purpose reporting guidelines. Third, I will discuss the recent developments on this topic in Canada, the CICA Exposure Draft and its recommendations and formulate my opinion on the framework. Fourth, I will support my opinion by discussing trade-offs and professional judgment, both of which are often used by the profession in practice. Finally, I will summarize the whole paper and draw the conclusion: financial reporting should be allowed with differential for SBEs. Opinions presented in this paper are also extracted from published articles and papers as well as opinions from a chartered accountant, a banker who is a small business loan officer and an owner who operates a small telecommunications business enterprise. 4 ADMS 4510 Winter 2002: 202724318, Yu Jia. The Opinions on Small Business Reporting Big GAAP vs. Little GAAP The Big GAAP/Little GAAP debate has been ongoing for the last two decades. 1 Those who feel that complying with certain GAAP requirement is of limited value to private enterprises advocated simplified or different standards for small or nonpublic companies. They have called for two separate sets of accounting standards: one set for larger or public companies, i.e. Big GAAP, and another set for small or non-public companies, i.e. Little GAAP. The Big GAAP is the GAAP as it now exists. It prescribes extensive disclosure requirements for public companies because their financial statements are widely circulated and the users are at an unlimited number and variety. The Little GAAP is a simplified Big GAAP. Advocates of Little GAAP believe that it should be tailored to the small or non-public companies because the users of their financial statements are more limited in number. By complying with a simplified GAAP, SBEs will save the time and financial resources now consumed by the preparation of their financial statements as well as reduce the amount of irrelevant information to the users. GAAP is GAAP Some accountants have argued that reporting standards are reporting standards and they should be equally applied to all financial statements that purport to give a fair presentation. Rules are rules and they should be everybody’s rules, i.e. GAAP is GAAP. They believe that a strong body of GAAP cannot have differential application and that uniformity in the application of GAAP is vital to the CICA Special Committee on Standard-Setting – Report (1980), Financial Reporting by Small Business – A report of the Accounting Standards Committee (May 1984). 1 5 ADMS 4510 Winter 2002: 202724318, Yu Jia. comparability of financial statements. “To serve the financially unsophisticated reader, the financial report needs to use standards and methodologies that are consistent and uniform over time and across companies. Sophisticated users will analyze and manipulate the data for their own specific needs and interests. Both cases require consistent, clear and detailed notes to the financial statements that provide all of the relevant information so users can quickly and reasonably make assessments. It is not up to the company or its auditors to assume what the users want, or to assume that a reader understands the nuances of a reporting methodology.”ii (Ted Anderson, April 1999) I side the first argument and support the opinion that GAAP should be tailored to meet the needs of small business financial statements users. In order to establish a solid argument on this issue, I believe it is important to identify who are the users of a small business and what are the users’ financial information needs. Keeping these two questions in mind, I did some research and interviewed 3 persons who deal with small business in Canada. The Users The Users and their Needs According to the Study Group on Financial Reporting by Small Business Enterprises, for financial reporting purposes, SBEs are “entities other than public enterprises, cooperative organizations, pension plans and financial institutions.”iii (Andree Lavigne, Oct. 1999) According to the same article, “users of SBE financial statements are normally few in number, consisting mainly of bankers, 6 ADMS 4510 Winter 2002: 202724318, Yu Jia. owner/mangers, tax authorities and, in certain instances, venture capital providers. SBEs prepare GAAP financial statements primarily to meet their bankers’ needs.” (Andree Lavigne, ibd.) To further understand the users and their needs, I interviewed Mr. Kam Manhas, small business loans officer at CIBC, Mr. Jacques Demers, owner who operates his own business and Ms. Winnie Szeto, CA at Deloitte & Touche. I asked Mr. Demers, the owner of the small business, who the users of his financial statements were. The answer was “myself, Revenue Canada and my banker.” Mr. Demers operates the business himself. He makes every single management decision and gets involved in every transaction that takes place within the operations of the business. He has the greatest access to any financial/non-financial information of his own firm. “We have to file tax reports. As long as I can support my numbers, not a lot trouble. But the banks are pretty picky. I have to get my financial statements audited, very costly for an 11-person business. Besides the financial statements, they also ask me additional information such as collaterals and how much money I can make to pay back loan and interest. ” Jacques Demers, owner, Personal Interview, 20 February 2002. According to Mr. Manhas, a loan officer for small business, the most important information for a loan decision is the credit history of the business. Financial statements play a major role in bankers’ decisions concerning loans as the 7 ADMS 4510 Winter 2002: 202724318, Yu Jia. entity’s asset/liability situation will provide collateral and cash flow will provide repayment. Banks may require proof of the asset situation to make sure the assets stated in the financial statements are accurate. “… not all the information (in the financial statements provided by SBEs) is useful. Future cash availability is the biggest concern.” Kam Manhas, Banker, Personal Interview. 18 February 2002. Ms. Winnie Szeto, CA, shared her insight that “the key element is to understand who are the users of a company’s financial statements. A user is somebody who uses the information provided in the financial statements to make decision. Depending on how heavily they rely on the information, users can be classified as primary user or secondary. It is obvious that in Canada, owners are the primary internal users for a small business. Lenders or trade creditors are the primary external users of the financial statements of a private company. When you think of the relationship between a lender and a firm, they are not only users and preparers but also parties of a loan contract. So, if a bank can exercise its power to gain access to the additional information, so can other lenders. The specific information that a lender needs from a borrower is its ability to provide future interest and principal payment. This kind of information must be timely and relevant, …” Winnie Szeto, CA. Personal Interview. February 18, 2002. “In Canada, in most circumstances, the primary external users of the financial statements of privately held enterprises are lenders and trade creditors. The most crucial financial information for creditors is how much cash will be available for payment of the debt. The cash generating ability of the enterprise and short- 8 ADMS 4510 Winter 2002: 202724318, Yu Jia. term liquidity are of prime importance to short-term creditors. Long-term creditors will pay more attention to the earnings-generating ability…”iv (CICA Exposure Draft, Differential Reporting, September 2001) It is now clear that the users of SBEs are limited to a narrower range. The primary internal users for SBEs are the owners and the primary external users are the creditors who provide financial support to the SBEs. The creditors are seeking specific information, such as collateral and project cash flow, to make their credit decisions. In order to make sure that SBEs provide relevant and timely information to meet these specific information needs, the financial information provided for these users should be focused on these specifics rather than disclose a lot of other less relevant information. To further support this opinion, I will look at Information Asymmetry Theory and apply it to the case of the SBEs. Information Asymmetry Theory Information Asymmetry is a “unifying theme that formally recognizes that some parties to business may have an information advantage over others.” (William R. Scott, 2000) This theory provides a convenient context within which to consider the major issues associated with relations between business entities and their external financial statements users. Information asymmetry exists between those within a business and those who provide external financial support to the business, the creditors, because obtaining information is inevitably very difficult and costly for external users without the access and resources at the disposal of 9 ADMS 4510 Winter 2002: 202724318, Yu Jia. insiders. To overcome difficulties associated with information asymmetry and to improve the access to reliable facts and figures that would allow users to judge the performance of the companies, it is paramount to have rules and guidelines – GAAP, which imposes disclosure standards on financial statement preparation. Public companies have unlimited users who are using financial information for different purposes. To meet these all-purpose needs of users, it is appropriate to require extensive disclosure so as to shorten the information gap between preparers and users. In the case of SBEs, financial information is likely to be an important source, sometimes, the only source, of firm specific information. In this sense, the inherent risk associated with information asymmetry for SBEs is even larger than that for a public company. “Small business financial reports must provide specific information which can be used as a basis for enforcing contracts that permits lenders and borrowers, in this case, users and preparers, to make mutually acceptable agreements as to the actions each will take and the sharing of outcomes from those actions. Therefore, it is logical that we have to tailor current GAAP to meet this need and prepare the specific required information.” Winnie Szeto, personal interview. February 18, 2002. From both a user’s and theoretical point of view, I have showed that the needs for small business financial information are different from those of public financial information. The CICA Handbook, section 1000, states that the objective of financial statements is to communicate information that is useful to financial statements users in making their resource allocation decisions and/or assessing management stewardship (paragraph .15) and that the benefits expected to arise 10 ADMS 4510 Winter 2002: 202724318, Yu Jia. from providing information in financial statements should exceed the cost of doing so (paragraph. 16). It is, therefore, the information needs of users that should determine the content of accounting standards. In order to better meet this objective, SBEs should be allowed to report their financial statements with differential under GAAP. I will next illustrate how standard setters have responded to the challenges posed by the all-purpose financial reporting requirements and the alternatives they have developed to deal with this issue. International practices are examined first and then the Canadian practice is discussed. The purpose of presenting these international practices is to provide a broader background and knowledge on this topic. This process will clarify the issues associated with the introduction of differential reporting and hopefully alternatives that better fit Canada’s own circumstances. Foreign Practices UK In November 1997, the Financial Reporting Standard for Smaller Entities (FRSSE) was first issued “…with the aim of producing a small company reporting framework to influence the development of reporting for the next 10 to 20 years.” v Institute of Chartered Accountants of Scotland, “Breaking the Code… A Better Reporting Framework for Small Companies.” October 1998, pp.5. It defined small businesses under Companies Act of 1985 and it distinguishes small businesses from the body of companies as a whole in terms of the form and the nature of their 11 ADMS 4510 Winter 2002: 202724318, Yu Jia. statutory financial statements. The qualificationsviof a small business must satisfy any two of the following conditions: a. A turnover of not more than 2.8million British Pounds2; b. A balance sheet total of not more than 1.4 million British Pounds; and c. No more than 50 employees. “It is designed to provide smaller entities with a single accounting standard tailored to their particular circumstances. The FRSSE sets out a simplified version of all current UK standards but excludes a number of disclosure and presentation requirements and provides a few measurement simplifications (for example, the asset and the liability related to a finance lease are stated at the fair value of the asset, not at the present value of the minimum lease payments, unless fair value is not a realistic estimate). The FRSSE is not compulsory, but when a small company chooses to adopt the FRSSE, it adopts all of it, and the financial statements state that they have been prepared in accordance with it.” CICA Exposure Draft, Differential Reporting. September 2001. pp.18. “Research commissioned by the Institutes of Chartered Accountants in England and Wales, Scotland and Ireland on samples of eligible companies showed that over 40 percent had adopted the FRSSE as of 1999. A more recent survey by the Association of Chartered Certified Accountants of UK members in practice indicated that over 80 percent of those surveyed used the FRSSE when preparing accounts on behalf of eligible clients. The UK Accounting Standards Board (ASB) has established a committee on Accounting for Smaller Entities 12 ADMS 4510 Winter 2002: 202724318, Yu Jia. which, on a regular basis, recommends to the ASB how new standards or revisions to existing standards should apply to smaller entities.”vii Ibid. pp.19. Australia “The Australian Accounting Research Foundation, in its first Statement of Accounting Concepts, linked the obligation to prepare general purpose GAAP financial statements to the existence of external users dependent on financial statements to make decisions. The following factors may be considered to determine whether an entity is a reporting entity: Separation of management from economic interest; Economic or political influence; and Financial characteristics (the Statement of Accounting Concepts mentions the following, with no quantification: value of sales or assets, number of employees or customers or level of indebtedness of the entity). In a more specific way, the Australian corporations law states that small proprietary companies have to prepare a financial report only if shareholders with at least 5 percent of the votes give the company the direction to do so, or if it is controlled by a foreign company. In addition, the direction may specify that the financial report does not have to comply with some or all of the accounting standards. A company is classified as small for a financial year if it satisfies at least two of the following tests: Gross operating revenue of less than Aus$10,000,000 ($8,000,000) for the year; “The UK government has announced its intention to raise these size parameters. Revenue threshold, for example, is expected to be increased to 4.8 million British Pounds.” CICA Exposure Draft, “Differential 2 13 ADMS 4510 Winter 2002: 202724318, Yu Jia. Gross assets of less than Aus$5,000,000 ($4,000,000) at the end of the year; and Fewer than 50 employees at the end of the year.”viii CICA Exposure Draft, “Differential Reporting”, September 2001. pp.20. New Zealand “The Financial Reporting Standards Board of New Zealand implemented a Framework for Differential Reporting in 1997. An entity qualifies for differential reporting options when it does not have public accountability and: At the balance sheet date, all if its owners are members of the entity’s governing body; or The entity satisfies at least two of the following size tests: - total revenue not exceeding NZ$5,000,000 ($3,200,000); - total assets not exceeding NZ$2,500,000 ($1,600,000); and - average number of employees not exceeding 20. Qualifying entities are granted a number of disclosure exemptions but also a few different measurement treatments (for example, the taxes payable basis is allowed, and long-term contracts may be accounted for using the completed contract method). The Framework for Differential Reporting allows selective application of the options provided. An entity that opts for differential reporting must disclose how it qualified and what exemptions it has applied.”ix CICA Exposure Draft, Differential Reporting, September 2001. pp.21. Reporting”, p.5. 14 ADMS 4510 Winter 2002: 202724318, Yu Jia. US “In the United States, compliance with US GAAP is required for public companies subject to regulation by the US Securities and Exchange Commission. Other companies may choose to comply with it voluntarily or for contractual reasons. Essentially, non-listed companies are permitted to prepare their financial statements on other comprehensive bases of accounting (OCBOA). Those bases include the US tax basis, the cash basis of accounting or a modified cash basis of accounting. Financial statements prepared on another comprehensive basis of accounting should include in the notes all appropriate disclosures under the basis of accounting applied, as well as disclosure of the differences from GAAP (however, the effect of the differences need not be quantified). A number of issues have been raised by American auditors as to how to assess the adequacy of these disclosures.”x CICA Exposure Draft, Differential Reporting, September 2001. pp.17. International “At the international level, the Statement published by the Board of the International Accounting Standards Committee in December 2000 recognized that demand exists for a special version of International Accounting Standards for small enterprises. The UN’s intergovernmental group on International Standards of Accounting and Reporting (ISAR) has recently set up a working group with the objective of preparing proposals for a differential reporting model linked to International Accounting Standards. The expected outcome is an ISAR guideline intended to be a non-mandatory aid for regulators in developing countries.”xi CICA Exposure Draft, Differential Reporting, September 2001. pp.23. 15 ADMS 4510 Winter 2002: 202724318, Yu Jia. Size Issue Identifying which entities qualify for the different bases of reporting is a key consideration in all above foreign alternatives. Having presented the above international experiences, I would like to address this key issue, as it is the premise for introducing the model of differential reporting. Where should be the cut-off? Should it simply be the size using revenue, asset or employee as a measurement or measurements? As discussed above, the UK FRSSE applies to small companies as defined in company legislation. The criteria are based on revenue (2.8 million British Pounds), total assets (11.4 million British Pounds) and average number of employees (50 people). The New Zealand standardsetting body includes as a further criterion the involvement of all owners of an enterprise in its governing body. People who favor a size test believe quantitative measurements are a good surrogate for assessing the cost-benefit trade off. However, “This is very arbitrary and very rigid. It simply undermines the underlying reasoning for introducing small business accounting – to meet users’ needs.” Winnie Szeto, CA. Personal Interview, February 18, 2002. I hold the same opinion as that of Winnie Szeto: the users should be the criteria to determine if a company can comply with differential reporting guidelines. How Canadian deals with this size issue will be presented later in this paper. 16 ADMS 4510 Winter 2002: 202724318, Yu Jia. Recent Developments in Canada Background People have advocated simplified or different standards for small or non-public companies for the last two decades3. In 1995, when CICA issued Section 3860, FINANCIAL INSTRUMENTS – DISCLOSURE AND PRESENTATION, strong arguments were brought into the spotlight that it was unnecessarily demanding for private enterprises. “Subsequently, application of INTERIM FINANCIAL STATEMENTS, Section 1751, and INCOME TAXES, Section 3465, has been deferred for enterprises other than public enterprises, co-operative organizations, deposit-taking institutions and life insurance enterprises, pending the completion of the project on differential reporting.”xii CICA, Exposure Draft, Differential Reporting, September 2001. Footnote, p.2. In Canada, several indicators underline the need for differential reportingxiii: Public accountants are reporting increasing concerns of their clients regarding the work and related costs necessary to comply with certain GAAP requirements that are perceived as primarily aimed at public companies and of limited value of private enterprises. To limit the costs of the engagements, some private enterprises have chosen to depart from GAAP on certain issues, with the result that the audit or review reports have contained a reservation noting the departure. Other private enterprises no longer have their financial statements audited or reviewed by their public accountants, preferring instead a compilation. 17 ADMS 4510 Winter 2002: 202724318, Yu Jia. In a compilation engagement, the financial statements commonly depart from GAAP in some respects and the public accountant provides no assurance concerning those financial statements. CICA, Exposure Draft, Differential Reporting, September 2001. pp.7. In 1998, a Research Report was commissioned by AcSB “to examine how the financial information needs of providers of capital to small business enterprises might be met more effectively, and the degree to which reporting accordance with GAAP could be modified to meet those needs.” CICA , Exposure Draft, Differential Reporting, September 2001. pp.10. To explore this area, the Study Group on financial reporting by small business enterprises held consultative meetings throughout the country, met with representatives of major Canadian banks and posted a survey on the CICA website. The purpose of the survey was to find adequate solutions for the improvement of financial reporting by SBEs and for better meeting the needs of users of SBE financial reports. Based on the research and survey results, the Study Group completed the Research Paper, “Financial Reporting by Small Business Enterprises” in May 1995. According to this report, small businesses and their stakeholders do have unique reporting needs: SBEs prepare GAAP financial statements primarily to meet their bankers’ needs. According to the Study Group, some of the information required under GAAP is clearly of little relevance to SBEs. The Research Paper also proposed that differential reporting be established within Canadian GAAP. “… accounting rules governing SBEs CICA Special Committee on Standard-Setting – Report (1980), Financial Reporting by Small Busienss – A report of the Accounting Standards Committee (May 1984). CICA Exposure Draft, “Differential 3 18 ADMS 4510 Winter 2002: 202724318, Yu Jia. would be permitted to differ from accounting rules applicable to public enterprises when such rules do not meet the financial reporting needs of SBEs or when the cost of applying the rules would outweigh their potential benefits for these enterprises.”xiv Peter Mart, CA Magazine. August 2000. Following the publication of this Research Report, AcSB established the Differential Reporting Advisory Committee as a standing committee to provide input to the standard-setting process concerning financial reporting by SBEs. The Exposure Draft In 2001, CICA published DIFFERENTIAL REPORTING Exposure Draft: “ACCOUNTING STANDARDS BOARD PROPOSED ACCOUNTING RECOMMENDATIONS – DIFFERENTIAL REPORTING EXPOSURE DRAFT” was published in July 2001 and “BACKGROUND INFORMATION AND BASIS FOR CONCLUSION – DIFFERENTIAL REPORTING EXPOSURE DRAFT” was published separately in September 2001. In the Exposure Draft, the Board again defined the users of SBEs’ financial information and their needs. Based on the users and users’ needs information, the AcSB concluded that uniform application of all accounting standards to all types of enterprises is no longer appropriate. It also supports partial differentiation on the basis of the objective of decision usefulness of financial information and cost/benefit considerations.4 Reporting”, footnote, p2. 4 CICA, Exposure Draft, “BACKGROUND INFORMATION AND BASIS FOR CONCLUSION – DIFFERENTIAL REPORTING EXPOSURE DRAFT”. September, 2001. pp. 26. 19 ADMS 4510 Winter 2002: 202724318, Yu Jia. CICA, Exposure Draft, “DIFFERENTIAL REPORTING”. July 2001. The Differential Reporting Framework Eligible Entities and Size Issues The framework tackled the size issue by examining the characteristics of users and adopted a qualitative approach. The board recognized that “Regardless of their size, all private enterprises share a common feature that distinguishes them from publicly accountable entities: they have a much narrower range of users of their financial statements. Differential reporting is justified by the users’ characteristics rather than by the enterprise’s own characteristics. While medium and large private enterprises have more financial resources and therefore may be able to bear higher reporting costs than small ones, cost per user may still be excessive for those enterprises relative to the benefits to be derived by a small group of users.” Under this principle, the AcSB concluded that an entity should meet the following two conditions in order to comply with differential reporting: No public accountability; and The owners’ unanimous consent in writing. “The requirement of owners’ unanimous consent may act as an implicit size test, as it may be harder to obtain this consent in larger private enterprises with a relatively large number of shareholders. In practice also, lending institutions will have a strong say in determining when differential reporting is acceptable. Lenders’ acceptance of differential reporting may vary, depending on an enterprise’s characteristics, circumstances and the type and size of loan. As a result, under differential reporting the basis on which an enterprise’s financial 20 ADMS 4510 Winter 2002: 202724318, Yu Jia. statements are prepared will be determined more explicitly by the needs of the users of the individual enterprise’s financial statements.”xv CICA, Exposure Draft, Differential Reporting, pp. 46. I, personally, strongly believe that this approach is a great alternative for the size issue because it was based on the needs of financial-statement users’ needs and is a good reflection of the financial statement objective as indicated in CICA Handbook, section 1000. It also strongly supports my contention in this paper that it is the information needs of financial-statements users that determine the content of accounting. Options The following sections were approved by the AcSB (subject to written ballot): Section 1590, Subsidiaries and Section 3055, Interests in Joint Ventures: use of the equity method and the cost method. Section 3050, Long-term Investments: use of the cost method. Section 1751, Interim Financial Statements: presentation of annual comparatives when year-to-date comparatives have not been previously prepared. Section 3240, Share Capital: limitation of the disclosure to issued classes of shares. Section 3465, Income Taxes: use of the taxes payable basis. 21 ADMS 4510 Winter 2002: 202724318, Yu Jia. Section 3860, Financial Instruments – Disclosure and presentation: preferred shares issued in specific tax planning arrangements may be presented as equity. Amendments were also made to Financial Statement Concept, Section 1000, to emphasize cost/benefit trade-offs for individual entities. The concept of differential reporting may still be controversial, but the framework presented by the Exposure Draft was assessed highly in relation to users’ needs. If the profession agrees that the financial statements should communicate information that is useful to financial statements users in making their decisions, I do not see why it is not a better idea to better fit these needs by allowing reporting with differential for SBEs. Trade-off and Professional Judgment I stated previously in this paper that some accountants argue that rules are rules. They believe that a strong body of GAAP cannot have differential application and that uniformity in the application of GAAP is vital to the comparability of financial statements. However, I believe that comparability should not be used as an argument because it is fundamentally inconsistent with providing accounting alternatives. When a conflict arises between the characteristics of relevance, reliability, comparability and understandability, a trade-off needs to be found that enables the objective of financial statements, i.e., the decision usefulness, to be met. This trade-off decision requires professional judgment. Professional judgment is often mentioned in an accounting environment. To decide which 22 ADMS 4510 Winter 2002: 202724318, Yu Jia. inventory valuation method better suits the company requires professional judgment. To decide what would be a good estimate of bad debt allowance requires professional judgment. These are only two of the many examples of using professional judgment for accountants. CICA Handbook section 1500.06 states: “No rules of general application can be phrased to suit all circumstances or combination of circumstances that may arise and the determination of what constitutes fair presentation or good practice in a particular case requires the exercise of professional judgment.”xvi CICA Handbook – Volume 1, section 1500.06. This indicates that GAAP cannot cover every accounting situation and therefore requires accountants to use their professional judgment to deal with different situations. For SBEs, it is clearly a situation where the group of users and their specific needs can be identified and where the needs are different from those of public companies. Given this fact, shall we apply the same guidelines and leave the rest to the professional to make their own individual judgment or would we be better off to tailor our rules to better fit the circumstances? I firmly believe that if we recognize the great needs differences and leave it all to professional judgment, the latitude for information interpretation and manipulation is so large that it will lead to confusing, ambiguous and misleading information. I am also convinced that allowing reporting with differential for SBEs will reduce accounting policy ambiguities and loopholes and provide a more consistent accounting basis for small business financial information. Therefore, we should allow differential reporting for small business enterprises. 23 ADMS 4510 Winter 2002: 202724318, Yu Jia. Summary and Conclusion After introducing the two arguments regarding the issue of differential reporting, I presented my opinion that the needs of financial-statement users determine the content of accounting standards and if the needs of the users are significantly different and identifiable, reporting should be allowed with a difference. To support my opinion, I did a lot research and interviewed a banker, a small business owner and a CA who deals with small business to identify who are the users of small business financial information and what their needs are for the financial information. My interview results concurred with other research papers on the fact that the users of small business enterprises are different from those of public companies and their needs are more specific. These results indicated the need for a tailored GAAP for SBEs. I then reviewed how foreign standard-setters responded to this situation and expressed my opinion on how the size-issue should be handled: it should satisfy the needs of users. The discussion was then moved to the Canadian context by introducing the background information of the Differential Reporting concept and the framework of the differential reporting model published by the CICA in September 2001. My conclusion was that given the fact that the users and the users needs are different from those of public companies, financial reporting should be allowed with a difference within GAAP for SBEs. For this reason, I named my paper “Reporting with Differential for Small Business Enterprises”. Although this concept may be controversial, it allows financial information to be communicated to the users and better fit their needs. The introduction of the differential reporting concept will set a precedent 24 ADMS 4510 Winter 2002: 202724318, Yu Jia. for more discussion in the accounting profession. Other topics such as government accounting may soon follow this path and argue that it is necessary to have a different set of GAAP or a differential reporting for government reporting, given the uniqueness of government entities and its financial information users. I believe that the concept of differential reporting is one of the milestones for accounting theory development and that it will evolve with time and the advances of the global economy and business practices. Endnotes: i American Institute of Certified Public Accountants, Report of the Private Companies Practice Section on Standards Overload, August 1996, p.1. ii Ted Anderson, “Tailor-made, or one-size-fits-all?” AK/ADMS 4510, Course Kit, p.137. iii Andree Lavigne, Standards with a differential, CA Magazine, Toronto, Oct. 1999. iv CICA Exposure Draft, Differential Reporting Background Information and Basis for Conclusions, September 2001. pp.28. v Institute of Chartered Accountants of Scotland, “Breaking the Code… A Better Reporting Framework for Small Companies.” October 1998, pp.5. vi Ibid, pp.7. vii Ibid. pp.19 viii Ibid. pp.20 ix Ibid. pp.21 x Ibid. pp. 17. Ibid. pp.23 xii Ibid. p.2. Footnote. xiii Ibid. pp.7. xiv Peter Martin, CA Magazine. All creatures great and small. August 2000, pp.47-48. xi xv xvi CICA, Exposure Draft, “Differential Reporting”. Pp.46. CICA Handbook, Volume 1, section 1500.06. 25 ADMS 4510 Winter 2002: 202724318, Yu Jia. Bibliography 1. 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Peter Martin, All creatures great and small, CA Magazine, Toronto, Aug. 2000. Vol. 133. 12. Richard G P McMahon, Financial reporting to financiers by Australian Manufacturing SMEs, International Small Business Journal, London, OctDec 1999. Vol. 18. 26 ADMS 4510 Winter 2002: 202724318, Yu Jia. 13. Ron Paterson, Widening the GAAP, Accountancy, London, May 2001. Vol.127. 14. Special Volume/Issue: International Briefing, Accountancy, London, Sep 1, 2001. Vol.128, Issue: 1297. 15. Ted Anderson, Sylvie Leger, Tailor-made, or one-size-fits-all? CA Magazine, Toronto, Apr. 1999. 16. Winnie Szeto, CA. Personal Interview. February 18, 2002. 27