Submission to the IASB - Technical Corrections

24 June 2005

Technical Corrections Comments
International Accounting Standards Board
30 Cannon Street
LONDON EC4M 6XH
UNITED KINGDOM
commentletters@iasb.org

Dear Sirs

Technical Corrections

The Group of 100 (G100) which represents the Chief Financial Officers of large business enterprises in Australia is pleased to respond to this Invitation to Comment.

The G100 supports the IASB’s initiative to make technical corrections to standards on a timely basis as clarification of the Board’s intentions enhances the implementation of standards and hopefully minimises the likelihood of subsequent requests for guidance and interpretation.

In view of the limited nature of the technical corrections the G100 is concerned that it could take up to six months to finalise a correction. While this is the completion of the process from an IASB perspective there are likely to be further delays in jurisdictions that adopt IASB Standards because of the need to incorporate the corrections in local requirements/law. In our view the process should be streamlined once the need for a correction is identified. The G100 supports the proposal to publish proposed amendments on the web site and to provide 30 days for comment. We believe this is adequate given the nature of the changes.

However, the G100 considers that assessment of items would be better undertaken by the IASB itself or a sub-committee rather than by the IFRIC Agenda Committee (AC). While we acknowledge that the distinction between technical corrections and interpretations will be difficult to determine in some cases, consideration by the AC can carry with it the implication that interpretation is necessary. The Board should play a central role in these decisions. The G100 considers that the policy statement would be improved if the process for dealing with editorial corrections was also outlined. For example, the distinction between technical and editorial corrections is not clear from the description in footnote 1 to paragraph 2.

One further issue is that the policy appears to be written to address those cases where a Standard is not yet effective. It is likely that in some cases the need for technical corrections will not be identified/completed before the effective date of a Standard. The retrospective application of technical corrections may cause difficulties for companies that have already applied the Standard and in those jurisdictions where Standards become part of the law.

Yours sincerely

Tom Honan
National President