New standard

The staff and Board follow pretty well the same process for the comments on the exposure draft as for the discussion paper. There are, though, some subtle differences in approach. In effect while the discussion paper is showing different possibilities, the exposure draft is saying: ‘OK, we have considered the possibilities, and this is our decision’. Consequently the Board is not looking for feedback on different approaches, but is rather giving constituents the opportunity to point out ‘fatal flaws’ in the proposal. Many respondents will, of course, still write in saying they prefer an alternative model, but unless they can advance some arguments that were not brought up at discussion paper stage, the Board is likely just to confirm its earlier decisions.

The main area for any flexibility between exposure draft and final standard is on the toughness of the standard. Due process requires that the final standard should not include any requirement that has not been exposed for comment. This means that if in re-debating the exposure draft position the Board decides to change something substantive, the proposal has to be re-exposed. Members prefer to avoid that if at all possible because it potentially delays the whole project by a further year (equally lobbyists against a proposal prefer to ask for re-exposure to delay implementation). As a consequence, the Board will tend to put tougher requirements in the exposure draft than it necessarily wants, so that it retains ...

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