- How are IFRS laid out? The core principles of any standard must be clearly worded. Other sub-principles are then articulated in a tree-like structure. Inconsistencies with other standards must be avoided, if possible, or fully explained. All application guidance and examples that are aimed at helping users to understand the principles have to justify their inclusion. Would anything be missed if they were deleted? If guidance is necessary, is the principle sufficiently clearly stated? Does the standard include bright lines and arbitrary limits? Why are these necessary? Does the transition follow the normal pattern? If not, why is a change proposed?
- How does this help prevent 'window dressing'? The use of principles eliminates the need for anti-abuse provisions. It is harder to defeat a well-crafted principle than a specific rule that financial engineers can bypass. A principle followed by an example can defeat the ‘tell me where it says I can’t do this mentality’.
- Impact on financial engineers:- If the example is a rule, then the financial engineers can soon structure a way round it. For example, if the rule is ‘when A, B and C happen the answer is X’, the experts would restructure the transaction so that it involved events ‘B, C and D’ and would then claim that the transaction was not covered by the standard. The abuse of unconsolidated special purpose entities, are an example of how well-intentioned rules present opportunities for financial engineering.
- But how would the system then work? A principle-based standard relies on judgements. Disclosure of the choices made and the rationale for these choices will be essential. If in doubt about how to deal with a particular issue, preparers and auditors should refer back to the core principles. The basis for conclusions should also include, in particular, the question of whether there is only a single view on how to tackle the economics of the situation. Often there are competing views—is one deemed to be more relevant? If so, the reasons for choosing that particular view should be explained in the basis for conclusions and the reasons for rejecting the others should be clearly stated.
- In litigation prone checklist driven regulations, can principles based IFRS work? Risk mitigation can be achieved via careful generation, collection and retention of documentation and by seeking of expert advice and the views of professional colleagues throughout the life cycle of transactions. Above all, defend those who make such judgements, document them and make an honest and fair attempt to meet the principle.
We humans are hardwired to defy authority. So if rules are proposed, 'search engine' type mentality looks for a loop hole to violate the spirit while obeying the letter. While a principles based approach, by its sheer ambiguity, would compel skilled professional judgement seeking to reflect the economics of a particular situation.Given that IFRS is an idea whose time has come, hopefully more rational(and well disclosed) choices will be made, equipping investors with tools/information to critique/appreciate that accounting.