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An Executive Guide to IFRS: Content, Costs and Benefits to Business by Peter Walton

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Exposure draft

Once the exposure period has ended, the staff begin the process of analysing the responses to the discussion paper. These responses are published on the IASB’s website, so constituents can access them. The Board will normally get at least a hundred comment letters after publishing a discussion document, but it could be twice that number if the subject is controversial. However, the number is sometimes exaggerated when members of an interest group write in separately. For example, when the IASB was looking at share-based payment, about 80 members of Financial Executives International sent in the same form letter. When the project is being run jointly with the FASB, both standard-setters may issue the same paper and then share comment letters.

Usually the first thing that the staff do is bring to the Board an agenda paper that provides an overview of the comments. This can be accessed either from the project page or from the meetings diary – but you need to research the date on which the item was debated. The paper will analyse the type of respondent (e.g. national standard-setters, audit firms, professional associations, etc.) and the nature of their comments. Some constituents respond systematically to all documents published for comment, while others write only if the issue directly concerns them. On the whole the staff are careful to avoid talking about numbers – they should not say ‘the majority of respondents approve …’, for example, because the respondents might ...

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