How IASB members use comment letters

John Hughes runs an excellent blog on Accounting and IFRS Standards. In a recent post Language barriers and the IASB, or: please read the letter that I wrote! | John Hughes IFRS Blog (disclosurehub.org), John Hughes commented on my post Language Barriers to commenting on IASB proposals – Accounting Miscellany

I need to pick up on one point he made there. He says:

“It seems to be taken as a given that Board members would seldom if ever see the comment letter themselves, relying mostly or completely on those staff summaries. No doubt this is a practical accommodation to time and energy constraints, but as I wrote here Talking to investors, whoever they are… | John Hughes IFRS Blog (disclosurehub.org), the lengthy and deeply-considered submissions from some respondents (whatever their degree of stylistic eloquence) may deserve better than to be boiled down into a relatively brief synopsis of what “most respondents” versus “a few respondents” had to say on the main points.”

My earlier post has a section describing ‘how information in comment letters reaches IASB members’. I explained there how IASB staff summarise and aggregate points from comment letters. I didn’t describe how IASB Board members have direct access to comment letters, and how they use comment letters.

IASB Board Member’s access to comment letters

I will describe how that access worked when I retired from the IASB staff 2½ years ago. I’d be surprised if the process has changed since then.

  • All comment letters are made available to all Board members electronically and, if they wish, also in hard copy.
  • During the comment letter period and for some time afterwards, Board members spend a lot of time reading comment letters. When the IASB first started up in the early 2000s, my impression was that all Board members used to read in depth all (or very nearly all) comment letters on all projects. Though I don’t know, I suspect some Board members may have become slightly more selective over the years, as volumes increased.
  • The IASB staff input all of the text from each comment letter into a database, organised by topic. The database makes it easy to look at, say, all responses to an exposure draft’s question 3. The database is mainly for the IASB staff to help them analyse responses and arguments in preparing staff papers. But Board members also use it themselves throughout a project to varying degrees, depending on the topics and depending on that member’s interests and preferred working methods. Some Board members interrogate the database intensively and extensively to dig deeper into topics that interest them. Others use it much less or perhaps not at all.
  • At each stage during a project, Board members can read an entire comment letter or can dig into individual topics on the database.

As projects progress

The way Board members work with comment letters evolves naturally as a project progresses.

  • During the comment period and for some time after the comment deadline, Board members read whole comment letters. Reading whole letters is important to understand the tone and nuances underlying comments, and to understand how a respondent’s views link to their views on other topics. In my experience, all Board members spent a lot of time reading whole comment letters at this stage.
  • Over time as the database fills up, some Board members may start to use the database alongside reading whole letters, or perhaps even instead of whole letters.
  • Once the staff papers start becoming available, Board members naturally start to rely more on the papers, which summarise what is in the comment letters. Even at this stage, Board members may well still read those whole letters that they had not yet picked up in their initial reading—but this may vary somewhat by Board member.
  • As the Board’s discussions progress, staff papers should provide all the information the staff think Board members need for the discussion at that meeting. Some individual Board members may choose to use the database to dig deeper into some topics, but if the staff do a good job Board members shouldn’t need to do that.

One final point on the process.

IASB Board members and the IASB staff need to work with full comment letters and understand each letter holistically. They rightly spend a lot of time doing this in the periods just before and just after the comment deadline.

But it would be a mistake to think that the IASB (or any such body) could somehow choose to work solely with full comment letters throughout the next round of discussions. On large projects, the IASB often receives 5,000 or more pages of comment letters. No human being can hold all that information in their head for many months. Summarising and aggregating the information from comment letters into staff papers is not just ‘a practical accommodation to time and energy constraints’: it is a pre-requisite for making the work possible at all.

Board members need both the full comment letters and summaries. They get both and they use both fully.       

How can people see that IASB members read comment letters?

John Hughes also says: ‘there’s no way of knowing whether the IASB’s degree of engagement with such submissions (even at the staff level, let alone that of the Board) is equal to the effort put into them.’ And he goes on to say ‘if “linguistic distance” doesn’t necessarily impede the chances of your much labored-upon comment letter being read and relished by the Board, that may only be because those chances barely existed in the first place’.

In fact, there are several ways of knowing how much effort IASB Board members and the IASB staff put into reading and understanding comment letters:

  • listening to IASB meetings. IASB members routinely demonstrate how much they have absorbed from reading comment letters, and how much they engage with the comments made.
  • reading IASB staff papers and seeing whether the most important points are captured clearly—and in a form that makes it easy to retrieve the points in future discussions.
  • discussing projects with IASB members and the IASB staff in outreach meetings.
  • reading the feedback statement the IASB produces once a project is complete.

Having seen this process from the inside throughout the first two decades of the IASB’s existence, I know all Board members spend an enormous amount of time reading and digesting comment letters.

Feedback statements

John Hughes suggests:

‘imagine that, at the conclusion of a project, each comment letter – or at least each one meeting a certain quality threshold – were to be individually acknowledged on the website with a brief summary of how its main points were reflected in the Board papers and in the project’s ultimate outcome. Of course this would be much more work for the staff, but arguable not disproportionately to what’s requested of those making the submissions. And yes, I realize there’s no chance of this ever happening.’

The IASB does already do something like this. At least for major projects, the IASB does produce a feedback statement, explaining:

  • the main points raised; and
  • what actions the Board took as a result of those points, and why.

In some cases, the feedback statement is one part of, for example, a project summary or a snapshot. The IASB publishes some feedback statements as a separate document: an example is the feedback statement the IASB published in 2018 with the new Conceptual Framework for Financial Reporting Conceptual Framework Feedback Statement (ifrs.org)

2 comments

  1. Thank you Peter for your detailed commentary on my (evidently even more flawed than usual!) post. All the very best to you – John

    1. Thanks for your comment, John. And thanks for your original post. It made me realise I’d made a mistake in not also describing how Board members read the full comment letters.
      I always enjoy reading your blog.
      Peter

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