IASC Foundation Constitution Review

16 February 2004

Mr Tom Seidenstein
Director of Operations and Secretary
IASC Foundation
30 Cannon Street, London EC 4 6 XH
UNITED KINGDOM

Dear Mr Seidenstein

IASC Foundation Constitution Review

The Group of 100 (G100) is pleased to respond to the Invitation to Comment ‘Identifying Issues for the IASC Foundation Constitution Review’. Our comments are set out below:

1. Small and Medium-sized Entities (SMEs)
The G100 believes that the present statement of objectives is adequate in respect of dealing with SMEs in the business sector. Under existing arrangements the IASB can take account of the so-called special needs of SMEs and distinguish between consistent requirements for recognition and measurement by all reporting entities and providing relief in the form of differential disclosure requirements.

2. Trustees
The G100 believes that the present representation on the Board of Trustees is focused on Europe and North America and is in need of review. The G100 proposes that the distribution of membership should better reflect the involvement of other geographical areas to enhance the involvement in the IASB’s processes.

3. Board Membership
The G100 believes that the number of Board members should be reduced to ten members and that members should have relevant and recent experience in applying accounting standards. As such, we believe that the importance of relevant recent experience should limit the tenure of members.

4. IFRIC
The G100 believes that IFRIC members should be adequately remunerated for their involvement as the role of IFRIC is to provide interpretations and undertake such other projects as the Board directs. Adequate remuneration will help ensure that highly skilled and experienced people are attracted to participate. The G100 also believes that members should be required to physically attend meetings. While we acknowledge that from time-to-time attendance by teleconference or videoconference is unavoidable, we believe that this should only occur on an exception basis.

5. Due Process and Consultation
The G100 considers that the present due process in the development of standards is adequate. However, our recent experience and that of some of our members creates the impression that the Board is not listening to concerns raised by preparers. In this regard IASB members, particularly those with liaison responsibilities, may take a greater role to communicate decisions to stakeholders.

As part of the ongoing process of communicating with the IASB and optimizing participation in its activities, the G100 has recently established a forum of business representative groups which will meet with the Australian IASB liaison member and Australian member of the Standards Advisory Council on a regular basis.

Yours sincerely

John V Stanhope
National President

c.c. Mr Peter Day
SAC Member