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<strong>Sir</strong> <strong>David</strong> <strong>Tweedie</strong><br />

<strong>Chairman</strong><br />

International Accounting Standards Board<br />

30 Cannon Street<br />

London<br />

EC3M 6XH<br />

Dear <strong>Sir</strong> <strong>David</strong><br />

Round-table Meetings<br />

<strong>Financial</strong> <strong>Reporting</strong> <strong>Committee</strong><br />

22 May 2006<br />

We understand that the Board intends to hold round-table meetings later in 2006 to discuss<br />

its proposed amendments to IAS37 “Provisions, Contingent Liabilities and Contingent<br />

Assets”.<br />

At a recent meeting of The Hundred Group’s <strong>Financial</strong> <strong>Reporting</strong> <strong>Committee</strong> an opportunity<br />

was given for members to report on the Round-table meetings that were held in London in<br />

November 2005 to consider the Board’s proposals on the future accounting for business<br />

combinations. Five of the <strong>Committee</strong>’s members attended the meetings either as<br />

participants or observers. We are writing to offer our feedback with the intention of assisting<br />

you in planning for future Round-table meetings.<br />

Conduct of the meetings<br />

In summary, our members were disappointed with the conduct of the meetings. It was felt<br />

that the meetings were stage-managed and that proper consideration was not given to the<br />

fundamental principles underlying the Board’s proposals. Regrettably, there was the<br />

perception that Board members were intent on avoiding the fundamentals by quickly<br />

focussing the debate on the detailed matters raised in the comment letters that had been<br />

submitted by participants. It also has to be said that the rather aggressive way in which the<br />

meetings were conducted was not appreciated.<br />

Overall, our members unfortunately came away with the impression that they were dealing<br />

with closed minds.<br />

We believe that if the Round-table format is to operate effectively in the future it is important<br />

that participants feel that their voices are properly heard and that the issues that they raise<br />

are given full and proper consideration. Only then will more people be encouraged to join the<br />

debate. Otherwise, there is the danger that even those who currently take the time to<br />

participate will be turned off.<br />

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Some of our members attended Round-table meetings held recently by the United Kingdom<br />

Accounting Standards Board to discuss the Discussion Paper “Measurement on Initial<br />

Recognition” that was prepared by the Canadian Accounting Standards Board. It was felt<br />

that the format of those meetings – presentations by selected interested parties followed by<br />

an open-forum question and answer session – was more effective in facilitating a proper<br />

discussion of the issues.<br />

Timing of the meetings<br />

We accept that by the time an exposure draft has been issued entrenched positions are likely<br />

to have been established and, frankly, it would be difficult for the Board to change radically<br />

its proposals.<br />

We therefore believe strongly that exposure drafts on significant issues should be preceded<br />

by a discussion paper. At this stage, there would be the opportunity for the Board to respond<br />

to comments without feeling that it has to make an embarrassing u-turn. Consistent with this<br />

view, we believe that Round-table meetings would be and would be seen to be much more<br />

effective if they were held at the discussion paper stage.<br />

Roadmap for the future<br />

We acknowledge that the Round-table meetings on business combinations were somewhat<br />

experimental. Although we have our criticisms of those meetings, we believe that the<br />

Round-table meeting has an important role to play in the development of accounting<br />

standards. We are therefore pleased that the Board has decided to hold similar meetings on<br />

its proposals on provisions and contingencies.<br />

Following those further Round-table meetings we would encourage the Board to make it<br />

clear whether it intends to continue with the Round-table format and, if so, at what stage they<br />

will they will be incorporated into the due process surrounding the development of accounting<br />

standards.<br />

Please feel free to contact me if you wish to discuss our comments.<br />

Yours sincerely<br />

Ken Lever<br />

<strong>Chairman</strong><br />

The Hundred Group - <strong>Financial</strong> <strong>Reporting</strong> <strong>Committee</strong><br />

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