AICPA Files Comment Letter on Review of IASCF Constitution

The AICPA filed a comment letter on the review of the IASC Foundation’s (IASCF) Constitution. While expressing strong support for the objectives of the IASCF and the IASB, the Institute:

 Urged the IASCF to continue its efforts to secure permanent funding for the IASB’s activities. The Institute said the SEC should use part of the current levy on U.S. public companies for accounting standard-setting activities as a permanent funding source for the IASB.

 Supported the creation of a monitoring group, as envisioned by the IASCF, to formalize the link to public authorities. The Institute expressed support for the SEC having a seat on the monitoring group and recommends that the IASCF add a bank regulator to the group. If in the future many countries adopt the IASB’s standard for private entities, the AICPA believes the IASCF should increase private entity constituency representation on the monitoring group.

 Agreed with the IASCF’s recommendation that a memorandum of understanding between the monitoring group and IASCF should be exposed for public comment.

 Supported the establishment of operating protocols in a manner that fully maintains the IASB’s independence, while providing sufficient oversight so that individual countries don’t have a basis for “carve-out” exceptions to what the IASB promulgates.

 Supported the proposed IASB geographic composition and the increased board size as reasonable changes.

 Supported having a maximum of three part-time members of the IASB.

 Called for the Trustees Appointments Advisory Group (TAAG) to continue to have an important role to fill even with the creation of the monitoring group. Primarily, the TAAG will help ensure that the IASCF has a formalized mechanism to reach out to additional constituencies to gather “fresh” perspectives when identifying candidates to serve as IASCF Trustees.

The comment letter is available at www.ifrs.com/pdf/IASB_Comment_Letter.pdf.