Retos futuros para el IASB
Stephen A. Zeff
Rice University
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I. How should the IASB manage its future relations with the
SEC and FASB/FAF?
II. How should the IASB manage the diverse feedback it
receives on its agenda and drafts?
III. What steps is the IFRS Foundation taking to engage with
country regulators so that they will become vigilant and
proactive in securing the compliance by listed companies
with IFRSs?
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IFRS Foundation trustees’ strategy review 2011:
‘To support the IFRS Foundation’s interest in consistent
application of IFRSs and to comply with the IASB’s
standard-setting mandate, the Foundation and the
IASB should undertake [to] Establish formal cooperation arrangements with securities regulators,
audit regulators and national standard-setters to
receive feedback on how IFRSs are being implemented
and to encourage actions aimed at addressing
divergence.’
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IV. What steps is the IFRS Foundation taking to persuade
countries to require transparent disclosure of departures
from the full set of IFRSs for listed companies?
V. In order to promote genuine global comparability of
financial reporting, the IASB must take into account
differences in tax incentives and disincentives, and
business customs and practices – what will the IASB do
to promote genuine worldwide comparability?
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I. How should the IASB manage its future relations with the
SEC and FASB/FAF?
A. SEC
1. There is currently an absence of process between
the IASB and the SEC
2. The final Staff Report on its Work Plan, issued in
July 2012 under chief accountant Jim Kroeker,
who has departed, contained no recommendations
to the Commission for action
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a. Paul Beswick, a deputy chief accountant, was
named chief accountant in December 2012
3. SEC Chair Mary Schapiro has departed, and her
successor, Elisse Walter, will serve for only a few
months
a. President Obama has nominated Mary Jo
White, formerly a federal prosecutor, to chair
the SEC – her views on IFRS, if she has any,
are unknown
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4. SEC continues to be represented on the IFRS
Foundation’s Monitoring Board
5. Will the SEC’s lack of commitment to IFRSs
influence the commitment of other countries, such
as Japan, China and India?
B. FASB/FAF
1. The strong support of either convergence or
adoption under FASB Chair Robert Herz and FAF
Chair Robert Denham began to dissipate in
February 2009 with Denham’s departure – Herz
resigned abruptly in August 2010
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2. Once the ongoing major convergence projects are
completed (leases, revenue recognition, financial
instruments, insurance) – if they ever are –
convergence between the boards will come to an
end
3. IASB has already decided that it will complete the
conceptual framework on its own
4. Once convergence is over, whether the FASB will
endeavor to converge toward IFRS is not known –
divergence may occur
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5. Will there be an attempt to exclude American
representatives from the IASB Board and IFRS
Foundation trustees?
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II. How should the IASB manage the diverse feedback it
receives on its agenda and drafts?
A. There have been the following feedback groups
1. European Financial Reporting Advisory Group
(EFRAG), since 2001
2. IFRS Advisory Council (formerly SAC), since 2001
3. World Standard-Setters, since 2002
4. Capital Markets Advisory Committee (formerly
Analyst Representative Group), since 2003
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5. International Forum of Accounting Standard
setters (formerly National Standard-setters), since
2005
6. Global Preparers Forum, since 2008
7. Asian-Oceanian Standard-Setters Group (AOSSG),
since 2009
8. Emerging Economies Group, since 2011
9. Group of Latin American Standard Setters
(GLASS), since 2011
10. Pan African Federation of Accountants (PAFA),
since 2011
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B. In November 2012, the IASB proposed a 12-member
Accounting Standards Advisory Forum to meet four
times a year, to ‘rationalise its relationships’ with
national standard setters and regional bodies –
members must commit to support ‘a single set of high
quality globally accepted accounting standards’
1. In December 2012, FAF advised the IASB that the
criterion for participation should instead be
commitment to ‘highly comparable (but not
necessarily identical) financial reporting
standards…based on a common set of
international standards’
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2. On February 1, IASB responded: ‘The ASAF
members must formally commit to supporting and
contributing to the IFRS Foundation in its mission
to develop, in the public interest, a single set of
high quality, understandable, enforceable and
globally accepted financial reporting standards’
3. In January 2013, the UK, French, German and
Italian standard setters complained that a
membership of 12 is too few (especially the 2
allotted to the EU), it does not distinguish between
full adopters and non-adopters, and it gives
preference to regional bodies
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III. What steps is the IFRS Foundation taking to engage with
country regulators so that they will become vigilant and
proactive in securing the compliance by listed
companies with IFRSs?
A. Without a comparable high level of proactive
compliance by national regulators, worldwide
comparability is seriously diluted
B. There is a high variability in regulator performance
even in the EU
1. Sweden relies on a stock exchange to regulate
compliance with IFRSs
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2. In December 2012, Austria finally got round to
setting up an enforcement process – the last
country in the EU to do so – which will not take
effect until July 2013
3. Many regulators do not have sufficient staff and an
ample budget – and authority – to be effective
4. Regulators in Civil Code countries are unable to
require restatements
C. The European Securities and Markets Authority
(ESMA) has been making its own assessment of the
adequacy of companies’ financial reporting
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1. Hans Hoogervorst’s letter to ESMA of August
2011, expressing ‘great concern’ over companies’
unconservative impairments on Greek sovereign
debt, had an impact
a. ESMA: the issue is of ‘great importance’
2. In January 2013, ESMA criticized companies for
under-reporting their impairments of goodwill and
for inadequate impairment disclosures
D. The International Organization of Securities
Commissions (IOSCO) can do no more than cajole
regulators into becoming more proactive – is it
proactive enough?
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IV. What steps is the IFRS Foundation taking to persuade
countries to require companies and auditors to affirm
compliance with IFRS?
A. In the EU, companies and auditors are required to
affirm compliance with ‘IFRSs as adopted by the EU’ –
how does a reader outside the EU know to what
degree such an affirmation corresponds with ‘IFRSs
as issued by the IASB’?
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B. If Japan adopts IFRS, the plan is for companies and
auditors to affirm compliance with IFRSs, but with
‘Designated IFRSs’ if there are any differences
C. In Hong Kong, companies fully adopt IFRSs, but they and
their auditors are required to affirm compliance with Hong
Kong Financial Reporting Standards – how does a reader
outside of Hong Kong know that HKFRSs and IFRSs are
the same?
D. In 2008, IOSCO urged companies to divulge whether, and
to what extent, their financial statements comply with
‘IFRSs as issued by the IASB’
1. SEC insists on an affirmation of compliance with ‘IFRS
as issued by the IASB’ to avoid a reconciliation with
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US GAAP
V. In order to promote genuine global comparability of
financial reporting, the IASB must take into account
differences in tax incentives and disincentives, and
business customs and practices – what will the IASB do
to promote genuine worldwide comparability?
A. Uniformity of methods around the world is
impracticable – business cultures are different
B. How can a consolidation standard be adapted to
Japan and South Korea, where networks of affiliated
companies, known as keiretsu and chaebol, are not
headed by a parent company – it can’t
1. ‘Comparability is not uniformity’– IASB/FASB
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conceptual framework (2010)
C. How does the standard setter adapt its standards to
the way business is done in Islamic countries?
D. Increasingly, as the IASB’s standards are seen as
leading to more volatile net incomes or as adversely
affecting debt-equity ratios – or as not reflecting
reality – lobbying by interested parties becomes more
intense and insistent
1. Countries will sometimes decline to adopt
standards until they are revised (Malaysia on IAS
41; Malaysia, Singapore, the Philippines, India on
IFRIC 15) or exclude an industry segment until a
standard is issued (Canada on rate-regulated
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activities)
2. Brazil requires the equity method of accounting for
subsidiaries in parent-only financial statements –
instead of using cost or fair value
3. Argentina and Mexico do not allow banks to use
IFRS – and Singapore does not allow banks to use
the incurred-loss loan provisioning in IFRS
4. Endemic inflation in Latin America
E. IASB is now expected to conduct an ‘effect analysis’ as
part of judging the costs and benefits of prospective
standards – can such an analysis be truly global?
F. Possible conflict between securities market regulators
and prudential regulators
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VI. The task that lays ahead is a large one: how to maintain the
highest practicable degree of worldwide comparability by
securing the support of
1. standard setters or government agencies that
endorse IFRSs promptly and fully in their respective
jurisdictions,
2. external auditors who see to it that companies
adhere to all of the terms of IFRSs, and
3. regulators who proactively enforce compliance by
companies with IFRSs
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Also important is a vigilant financial press that draws
attention to deficient financial reporting
The IASB’s task is to issue standards that call for
accounting information which reflects economic reality
and is complemented to the extent necessary by full
disclosure of pertinent supplementary information
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