The AICPA’s senior technical committee for financial reporting advised the IASB to continue focusing on completion of a conceptual framework, including a presentation and disclosure framework. The IASB requested the feedback when it issued its Agenda Consultation 2011 in July.

Richard Paul, chair of the AICPA’s Financial Reporting Executive Committee (FinREC), sent a letter to IASB Chair Hans Hoogervorst on Nov. 30 commenting on the IASB’s agenda. The letter called on the IASB to establish fundamentals to guide the board as it continues to develop IFRS, so the standards satisfy objectives and are consistent and understandable.

The conceptual framework, Paul wrote, is needed to guide preparers of financial statements when they encounter gaps in the standards that are inevitable. The committee said the IASB has an opportunity to forestall disclosure overload while improving the quality of information provided by financial statements.

“It’s kind of like building a house,” Paul said in an interview. “You need a solid foundation to start from before you start making decisions about individual aspects of the house.”

Paul wrote that a disclosure framework would help the board rationalize requirements and could focus preparers on providing clear communication of matters that are important for financial statement users to understand.

The letter said the conceptual framework project should consider how consistency should be emphasized in the framework. If that concept were further developed, Paul wrote, the IASB’s decision on the level of specificity in individual subsequent standards projects or the accompanying implementation guidance would be informed with that concept.

The IASB’s Agenda Consultation 2011 is available at Paul’s comment letter is available at

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