31 July 2008

EFRAG draft comment on ED on improved Conceptual Framework for Financial Reporting

The Exposure Draft has been prepared as part of a joint project by the IASB and FASB and it sets out the boards´ proposal for the two first chapters of their proposed common framework.

EFRAG does still have concerns about aspects of the ED although it represents a significant improvement on the version that was set out in the earlier discussion paper.

• EFRAG remains strongly of the view that no part of the Framework should be finalised until the whole Framework is ready to be finalised, unless all the implications of the changes being made in the finalised bits of the revised Framework are identified at the ED stage and are reflected in the consequential amendments made at the same time. 
• EFRAG believes that information that is relevant to the capital providers ought also usually to be relevant to those managing that capital; and that the Framework could be improved by acknowledging that link.
• EFRAG think the ED’s comments on users’ interest in the financial performance of the entity do not seem to take sufficient notice of users’ interest in gross flows

• EFRAG believes that a comprehensive and in-depth debate is needed on the perspective from which financial statements should be prepared and that the material in the Basis for Conclusions on the subject is insufficient to enable that debate to take place.
• EFRAG remains uncomfortable with the proposal that the notion of ‘reliability’ should be replaced by the notion of ‘faithful representation’

Press release

© EFRAG - European Financial Reporting Advisory Group