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We see the periodic review of the IASCF Constitution as an important part of the IASCF’s processes, and are pleased that the IASCF is asking, through this latest paper, for comments on the issues on which the review should focus. Our detailed comments are set out in the appendix, but we wish to highlight some key points:
• We believe that a change is necessary concerning the IASB’s agenda process. We believe the current process needs to be more consultative. We also think it needs to be extended to major prioritisation and scoping decisions.
• Another change we think is necessary concerns decisions about re-exposure. We believe the IASB should be required to follow some sort of explicit process and explain the basis for its judgement that re-exposure is not necessary in cases where significant changes to ED’s have been made. The role of the Trustees would then be to ensure that the process has been properly followed.
• Moreover, improvements are also required as to how the constitution and those processes are implemented. We make some specific comments on this in our letter.
Finally, we note that the world has recently faced an unprecedented financial crisis. Voices have questioned the possible role of accounting requirements in the development of this crisis. In due course, it will be very important for all stakeholders to draw conclusions from this experience. In particular, it is of fundamental importance that the process of standard-setting is reviewed in depth to identify whether some areas need to be improved in light of the experience. It may be too early to do this in the context of Part 2 of the review of the constitution, but in the coming months, and certainly before the next review of the constitution in five years, we would urge the IASCF to carry out this analysis.
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