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FEE agrees that effects analyses should be embedded in the standard-setting process throughout the life cycle of a project. FEE believes that a clearer distinction should be made between effects analysis ex ante and ex post, since FEE believes that post-implementation reviews are different from ex ante effects analyses.
FEE believes that in particular at the stage where a decision is made to add a new project to the IASB agenda, there needs to be a clear problem definition of what issues a new project is seeking to address, as well as evidence of the expected effects.
Effects should include both micro-economic and macro-economic effects.
FEE favours a process that is both pragmatic and robust. The IASB should be responsible for performing effect analysis, and the effort involved should be relevant and proportionate.
For the effects analysis process to have genuine credibility, robust oversight by the Trustees’ Due Process Oversight Committee (DPOC) is paramount at all stages of the process to mitigate any self-review risk. This risk is particularly high, either real or perceived, at the stage of post-implementation reviews, and therefore warrants significant DPOC involvement.
Finally, FEE points out that the discussion paper can be improved by eliminating some sections that seem repetitive or unnecessarily detailed.