Conceptual Framework Discussion Paper: Notable Comment Letter from the Australian Heads of Treasuries Accounting and Reporting Advisory Commitee

Conceptual Framework Discussion Paper: Notable Comment Letter from the Australian Heads of Treasuries Accounting and Reporting Advisory Committee

The HoTARAC notes:

"HoTARAC has significant concerns on the discussion in a number of areas.

HoTARAC does not believe the discussion of topics proceeds in a logical progression from a coherent set of core principles. In HoTARAC´s view, this, at least in part, derives from:

• insufficient consideration of the objectives of financial reporting and their application to the topics at hand, and reliance on the existing chapters of the conceptual framework;
• delegation of core concepts, often fundamental to the topic discussed, to other projects; and
• the framework being developed to justify current practice, rather than from a sound conceptual basis.

The framework also appears to be developed in isolation from advances in related disciplines, such as communication, finance, economics and valuation with a consequent risk of loss of relevance.

Additionally, HoTARAC is concerned that the framework is being developed without consideration of the future direction of financial reporting, including the development of standards for the not-for-porfit and public sectors."

The complete comment letter is available HERE dated 2013-12-02 on Page 1.