2 November 1998
Mr. Ken Spencer
Chairman
Australian Accounting Standards Board
211 Hawthorn Road
Caulfield Vic 3162
Dear Ken
Superannuation and Post-Employment Medical Benefits
At its meeting on 22 October 1998 the National Executive noted the Boards announcement that it was considering alternative approaches to the recognition of actuarial gains and losses in respect of defined benefit superannuation schemes.
The National Executive expressed concerns about the potential effects of the Board requiring the immediate recognition of actuarial gains and losses in the profit and loss account. This approach was seen to be inconsistent with the objective that compliance with an Australian accounting standard would result in compliance with the equivalent IASC standard which would be endorsed by IOSCO and the SEC. The Group of 100 believes that the objective of IOSCO and SEC endorsement is to facilitate cross-border listings and capital raisings in the USA without the need to make reconciliations.
Yours sincerely,

Bryce JH Denison
National President
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