25 August 1999

The Standing Interpretations Committee
International Accounting Standards Committee
166 Fleet Street
London EC4A 2ES
United Kingdom

Dear Sir,

SIC D18 Consistency - Alternative Accounting Policies

The Group of 100 supports the draft Consensus that where an Accounting Standard permits choice of accounting policies or permits separate catergorisation of items the method selected by the entity should be applied on a consistent basis.

The Group of 100 also agrees that where the method chosen is changed that change constitutes a change in accounting policies.

While supporting the draft Consensus the Group of 100 is concerned that International Accounting Standards permit so many alternatives. The existence of these alternatives is inconsistent with the stated objective of achieving similar treatment of like transactions on a consistent basis for all enterprises and is inimical to ensuring comparability of financial statements. As such SIC-D18 is attempting to alleviate some of the consequences of being permissive and is not addressing the fundamental problem/issue of whether such choices should exist.

Yours sincerely,

Bryce JH Denison
National President

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