5 December 2006

Mr David Boymal
Chairman
Australian Accounting Standards Board
PO Box 204
COLLINS STREET WEST VIC 8007

Dear David

AASB’s Due Process

While not addressing the technical merits of the AASB’s rejection statement re accounting for the petroleum rent resource tax (PRRT) the Group of 100 (G100) wishes to express its concern about the process adopted by the AASB in dealing with the draft rejection statement relating to accounting for the PRRT.

The G100 believes that the AASB did not follow the practice for dealing with issue proposals under the Interpretations Model 2006. Due process is stated to involve publication of a proposed rejection statement on the website for an appropriate period prior to AASB meetings. We do not consider that the AASB provided constituents with an appropriate time to respond to the proposed rejection statement.

It was inappropriate for the AASB to finalise a rejection statement at its October meeting without placing it on the website for comment by constituents – a process which is similar to that adopted by the IFRIC in respect of rejection statements. Had the AASB observed this aspect of due process it would not have been necessary to subsequently invite comment on what was announced as a final rejection statement.

The G100 believes that if the Board is to continue the practice of issuing agenda rejection statements it should observe its own due process when doing so.

Yours sincerely

Tom Honan
National President