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An Analysis of the IASB’s Dissenting Opinions
Michael E. Bradbury* and Julie Harrison**
* Massey University
** University of Auckland
This draft: 10 October 2012
Initial draft: 29 March 2012
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An Analysis of the FASB’s Dissenting Opinions
ABSTRACT
In this paper we report the results of a content analysis of dissenting opinions found in
International Accounting Standards Board (IASB) standards. During 2002 to 2009 the IASB
issued 26 financial accounting standards or amendments to standards. Twenty-five of these
standards contained dissenting opinions. We identify and classify the arguments in the
dissenting opinions using the methodology of Bradbury and Harrison (2012). We compare the
results of this analysis to the analysis of the FASB dissenting opinions for the period 1981 to
2009 contained in Bradbury and Harrison (2012). The results show that the IASB standards
are characterised by a higher rate of dissent reflecting the greater diversity of the IASB board.
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An analysis of the IASB’s Dissenting Opinions
Introduction
A large body of research has examined constituent participation and lobbying of International
Financial Reporting Standards (IFRS) (e.g., Larson 2007, Georgiou 2010, Zeff 2010, Hansen
2011, Jorrison et al. 2012). Relatively fewer studies have examined the International
Accounting Standard Boards (IASB’s) due process. Fülbier et al. (2009) and Larson et al.
(2011) examine the role of academia in standard setting. Howieson (2009) examines agenda
formation. Whittington (2008) addresses the conceptual framework review. Larson and
Kenny (2011) examine the financing of the IASB. Chatham et al. (2010) examine issues
related to the development of international standards.
Dissenting opinions to International Financial Reporting Standards (IFRS) are an important
feature of the IASB’s due process. Dissenting opinions demonstrate the transparency of “due
process” by ensuring that all views have been considered. They improve arguments on
existing standards, because the basis of conclusion must consider dissenting arguments and
strengthen the counter arguments.
In this study, we analyze the content of IASB dissenting opinions, with a focus on the
arguments employed. That is, we apply content analysis to dissenting opinions and report
arguments based on themes relating to concepts (conceptual framework and non-framework),
logic, scope, outcome and due process. We also provide a comparative analysis and present
the corresponding results for FASB dissenting opinions over the period 1981 to 2009 reported
in Bradbury and Harrison (2012). An analysis of the arguments used in dissenting opinions
ought to be useful in the revision of the conceptual framework, thereby improving future
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decisions.
The results for IFRS dissenting opinions are likely to differ from those of the FASB
(Bradbury and Harrison 2011) for two main reasons. First, there is a difference in the level of
authoritative support of the conceptual framework between the FASB and the IASB. While
both the IASB and FASB use the Framework in the development of future standards, under
IFRS the use of the Framework is embedded in the selection of, and changes in, accounting
policies (i.e., IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors,
paragraphs 10-12). Second, the IASB has more diverse constituents than a national standard
setter, such as the FASB (Tokar 2005). In the next section we raise conflicting hypotheses
with regard to the frequency of dissenting opinions and the reliance on Framework arguments
and non-framework conceptual arguments in dissenting opinions. Thus, it is important to
examine IASB dissenting opinions, rather than rely on evidence from the results from FASB.
This is even more important because the IASB/FASB joint programme has stopped and the
IASB is continuing to develop its own Framework (IFRS Foundation 2012).
The next section of the paper develops the research questions, describes the data and how we
analysed the content of the dissenting opinions. Results are then presented including a
comparison of the analysis of the IASB dissenting opinions to corresponding data reported in
Bradbury and Harrison (2012). The paper concludes with a discussion of the relevance of this
analysis for both the IASB current conceptual framework project.
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Hypothesis Development, Method and Data
Hypotheses
Since the formation of the IASB in April 2001 it has assumed the role of global financial
reporting standard-setter. IFRS issued by the IASB are now required or permitted to be used
in more than 100 countries (IFRS Foundation 2011a), including most G20 countries, with the
major exceptions being the US, China, India and Japan. A key ongoing challenge facing the
IASB is demonstrating to stakeholders, notably the SEC, that it is a producer of high quality
standards (Zeff 2012).
The role of global standard-setter presents challenges for the IASB related to the growing
diversity of its members and constituents (Tokar 2005). Initially the IASB was dominated by
technical experts that were known to each other or had worked together previously as
national standard-setters. Subsequent recruits were less likely to be known by the existing
board, more likely to be users and not standard-setters, and were drawn from a wider pool of
nations (Zeff 2012). Such diversity in the composition and experience of the board will
inevitably create differences of opinions likely to impact the standard-setting process. Our
first hypothesis (1A) is that greater diversity in the IASB membership leads to more conflict
relative to a national standard-setter (i.e., the FASB).
The IASB has been subject to criticism related to the standard-setting process in relation to
potential bias and the impact of lobbying by constituents (Zeff 2002, 2012). Chatham et al.
(2010) argue that the IASB’s need for social approval can lead to greater flexibility in
standards (i.e., more accounting choice is incorporated to appease constituents, resulting in
lower quality standards). If this view is correct then as an alternative to 1A we hypothesize
(1B) that high levels of flexibility within a standard are likely to be associated with lower
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levels of dissent. Another argument giving rise to an expectation of a lower frequency of
dissenting opinions is that the IASB was willing to sacrifice diversity in order to produce a
volume of timely standards.
We hypothesize (2A) that the higher authoritative status of the Framework provided by its
recognition in IAS 8 will result in higher frequency of qualitative characteristics, than the
FASB dissenting opinions. An alternative hypothesis (2B) is that the diversity of IASB
membership will lead to greater differences of opinion on the importance (or weighting) of
different qualitative characteristics and in non-framework conceptual arguments.
Method and Data
In this paper we identify and classify the arguments in the IASB dissenting opinions using the
methodology of Bradbury and Harrison (2012), developed from Bennett et al. (2006) and Yen
et al. (2007). This methodology uses content analysis to extract meaning from the dissenting
opinions by identifying common themes, coding items of interest and analyzing coded text
using statistical techniques (Bechtel, 1997). Dissenting opinions are first separated into
‘dissenting issues’ (representing single, specific objections to standard) and then coded into
‘dissenting arguments’ (using coding themes specified in Bradbury and Harrison 2012 and
reported in Table 1 Panel A). Table 1, Panel B summarizes the relation between the
dissenting opinion, dissenting issue and dissenting argument.
We analyze all financial standards issued by the IASB as either IAS or IFRS since its
inception in 2001 until June 2020 (n=26).1 The termination date coincides with the departure
1 Copies of the dissenting opinions were obtained from IFRS Foundation (2011b).
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of Sir David Tweedie, the initial chair of the IASB. The selected text for analysis is the
dissenting opinion found in each accounting standard (n=25). The unit of analysis used is the
dissenting issue. Each opinion can have multiple dissenting issues (n=56). The majority of
dissenting opinions contained only one issue and the maximum is seven. Each issue can
have one or more dissenting arguments (n=218) and one or more “authors”.2 The dissenting
arguments were coded using the taxonomy in Table 1, Panel B. For consistency with prior
research, this taxonomy is the same as Bradbury and Harrison (2012), with minor
modifications to reflect new arguments raised in the IASB dissenting opinions. To ensure
the inferences drawn from our content analysis were “systematic, explicitly informed and
(ideally) verifiable” (Krippendorff, 2004, 25) identification of dissenting issues and the
coding of themes in dissenting arguments were performed by the two researchers
independently. This coding was based on the agreed taxonomy/coding manual (see
Appendix A). Any differences in coding by the two researchers were resolved by
consensus.
As an example of the coding process, the dissenting opinion to IAS 24 (related party
disclosures) contains one dissenting issue related to an exemption for government-related
entities. This issue is supported by three dissenting arguments coded as “costs versus benefits”
(“remove the unnecessary burden of collecting data”), “decision usefulness” (“the need to
inform investors”), and “comparability” (“no reason to make such a distinction”).
2 The “author” is the Board member who raises the dissenting issue.
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Results
Level of Dissent
Table 1, Panel B details the number of standards and dissenting opinions analyzed. Only one
standard did not have a dissenting opinion. This compares to 50 percent of FASB standards
which have dissenting opinions (Bradbury and Harrison 2012). In addition, the number of
dissenting arguments per dissenting opinion is higher for the IASB (8.76) than the FASB
standards (7.01), as shown in Table 2. This provides support for hypothesis 1A that the
diverse geographic and cultural backgrounds of the IASB standard-setters makes it relatively
more difficult to achieve unanimous agreement compared to the FASB (a national
standard-setter). The alternative hypothesis that flexibility in standards and consensus
required to produce timely standards have comprised the debate (resulting in fewer dissenting
opinion) is not supported.
Summary of Arguments
Table 2 summarizes the arguments in dissenting opinions coded in accordance with the
taxonomy in Table 1. Conceptual, logic, scope and outcome arguments are the most common
in IFRS dissenting opinions. From the 219 arguments raised in all dissenting opinions, 127
(58%) are conceptual arguments, 43 (20%) are logic arguments, and 17 (8%) are scope
arguments. Similar frequencies are observed in dissenting opinion in FASB standards during
the period 1991 to 2010. Relative to the FASB, the IASB dissenting opinions place a much
greater emphasis on outcome arguments (9% compared to 7%) and less emphasis on due
process arguments (2% compared to 5%). In relation to the second set of hypotheses, the
results provide initial evidence that the difference in the status of the conceptual framework
between the IASB and FASB is not significant enough to affect the relative weighting of the
arguments used to object to standards, with most arguments related to accounting concepts
and logic.
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Analysis of Specific Arguments
Conceptual Arguments
Table 3 summarizes the conceptual arguments in the dissenting opinions. Panel A comprises
“framework – qualitative characteristics”; Panel B “framework – other” and Panel C
“non-framework”.
The most commonly argued qualitative characteristic is reliability (25 argument or 20% of
total conceptual arguments, including the components of reliability). There are 6 arguments
specifically referring to reliability and 19 arguments referring to the components of reliability
(i.e., verifiability (0), neutrality (3), and faithful representation (16)). Comparability is the
second highest argued qualitative characteristic with 19 arguments (15%), followed by
decision usefulness (15), relevance and its components (11), cost-benefit (7), and
understandability (2). The concepts of predictive value, feedback value, verifiability,
materiality and completeness are not used. References to other parts of the conceptual
framework are reported in Panel B of Table 3. Six general references to the framework are
made, with nine specifically referring to definitions of elements of the financial statements
and one to risks and rewards.
The FASB’s dissenting opinions have a similar distribution. Most qualitative characteristics
are within + or – 2% of the FASBs. The IASB dissenting opinions have relatively fewer
arguments related to understandability 2% compared to 5%, more arguments related to
decision usefulness (12% relative to 6%) and more arguments referring to the elements of
financial statements (7% compared to 4%).
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Non-framework conceptual arguments raised in dissenting opinions are reported in Panel C
of Table 3. Popular non-framework arguments used in dissenting opinions relate to
accounting objectives3 (7), management intent (7) and complexity (6). Other arguments are
practical difficulties (3) and conventional practice (2). Less popular arguments were also
raised in relation to disclosure as a substitute for proper accounting (1), matching fair value
amounts (1), objectivity/subjectivity (1), risk and rewards (1), transparency (1) and
uniformity (1). The “other” arguments (2) cover a range of different concepts such as
references to comprehensive income or capital maintenance that are infrequently mentioned.
IASB non-framework conceptual arguments in dissenting opinions are similar to those in
FASB opinions, except that management intent has higher frequency and “other” arguments
are used less frequently.
Logic Arguments
Table 4 summarizes arguments that disagreed with the logic within a standard. Most of the
arguments relate to the external consistency of the accounting treatment in other IASB and
similar pronouncements (22). External consistency is concerned with the consistency with
other IFRS. Arguments were also raised in relation to the internal consistency within the
standards (8) and general claims about the lack of logic (13). The IASB dissenting opinions
contain more logic arguments than the FASB, but the claims refer more generally to the lack
of logic than identify specific internal inconsistencies.
3 Arguments that refer to the objectives of the IASB or standard setting in general are classified as “other”
arguments reported in Table 8.
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Scope Arguments
Table 5 summarizes the scope arguments. In 5 (2) of these dissenting opinions the authors
objected to a narrow (wide) scope. Other scope arguments relate to the inappropriateness (2)
of the standard or that other projects (8) needed to be completed first (e.g., the projects
considering the definition of a reporting entity (IAS 27) or lease accounting (IAS 17)). Most
scope arguments in the FASB’s dissenting opinions relate to inappropriateness. In comparison,
the IASB are concerned with the completion of other projects. This is also consistent with the
emphasis on external consistency in Table 4.
Outcome Arguments
Table 6 summarizes outcome arguments, where the author considers the standard will have a
negative impact on the users of financial statements. The IASB has almost twice as many
outcome arguments per dissenting opinion than the IASB. Furthermore, the arguments are
very different. The most prevalent outcome arguments raised are that the standard provided
no improvement (9) and was susceptible to earnings management (6). This is consistent with
the high frequency of management intent observed in Table 3. Given that the IASB have no
jurisdiction over the enforcement of IFRS, these dissenting opinions reflect a concern over
enforcement.
Due Process and Transitional Arguments
The due process and transitional arguments are summarized in Table 7. Due process
arguments relate to the process the IASB follows in implementing the standards. Transitional
issues relate to the transitional provisions, or lack of them, contained in the standards. Due
process arguments are infrequent (4) and less than half that of the IASB. This is perhaps
surprising, given the transitional issues facing wholesale adoption of IFRS. This suggests that
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the standard-setting processes followed by the IASB are generally regarded as robust by
board members.
Other Arguments
Other arguments, summarized in Table 8, include residual arguments not elsewhere classified
in the taxonomy. Only standard-setting objectives, related the IASB’s or the accounting
profession’s role and objectives, are identified (8). Unlike the FASB, no evidence-based or
“personal belief” arguments were identified.
Overall, the results of the analysis of the specific arguments confirm our initial conclusion in
relation to the second set of hypotheses, that the difference in the status of the conceptual
framework between the IASB and FASB is not sufficient to significantly affect the relative
weighting of the arguments used.
Conclusion
In this paper we report the results of a content analysis of dissenting opinions in International
Accounting Standards Board (IASB) standards. All dissenting opinions (25) released by the
IASB in the period 2001 to 2010 are analyzed. We also provide comparative data from FASB
dissenting opinions (Bradbury and Harrison 2012).4
From this analysis we make the following observations. A much higher proportion of IFRS
4 We acknowledge that this comparison is imperfect, because (1) different time periods and (2) different
standards were issued.
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standards have dissenting opinions (96%) compared to FASB (50%). This supports
hypothesis 1A that board diversity reduces the consensus on issuing accounting standards.
There is no support for the alternative arguments that accounting flexibility within standards
or the need for timely set of standards increases consensus.
However, the distribution of arguments across our taxonomy is similar between the IASB and
IASB dissenting opinions. There is a slightly higher rate of conceptual arguments raised per
dissenting opinion for IASB (5.08) relative to the FASB (4.14). However, there are similar
proportions between framework and non-framework. Non-framework conceptual arguments
in the IASB dissenting opinions are dominated by management intention, complexity and
accounting objectives. Accordingly, we reject our second set of hypotheses that the
difference in the status of the conceptual framework between the IASB and FASB will result
in a higher level of arguments in relation to qualitative characteristics and to greater
differences of opinion on the importance (or weighting) of different qualitative
characteristics and non-framework conceptual arguments.
The level of dissent in the IASB standard-setting process suggests the greater diversity of its
members leads to higher levels of dissent compared to a national standard-setter, such as the
FASB. However, this diversity does not appear to have a significant impact on the nature of
the arguments raised by the IASB compared to the FASB. Further, very few due process
arguments are raised in relation to the IASB standard-setting process. Therefore, the
diversity of the board does not appear, of itself, to generate different demands on the
standard-setting due processes.
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Conceptual framework arguments (e.g., qualitative characteristics such as consistency and
reliability) are the most frequently used arguments by both the IASB and FASB. There
appears to be no significant difference in the rate these arguments are used, suggesting that
the perceived status of the conceptual framework for both organizations is similar.
Systematic use of non-conceptual framework arguments by the IASB (and FASB) suggests
such concepts ought to be discussed and either accepted or rejected in any conceptual
framework revision.
Logic arguments are common for both the IASB and FASB, but the emphasis for the IASB is
on external consistency with other IFRS. This many reflect greater pressure on the IASB to
develop consistent standards, compared to a national standard-setter, for the purpose of
promoting its processes as high quality and encouraging countries to adopt IFRS.
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TABLE 1 Coding of Argument
Panel A: Taxonomy of Arguments
Conceptual arguments – conceptual arguments focusing on the deficiencies in the
standard. These are classified as either conceptual framework – qualitative arguments
(e.g., qualitative characteristics of information), conceptual framework – other
arguments (e.g., definitions of elements of the financial statements) or non-
framework arguments.
Logic arguments - arguments that point out inconsistencies in the standard. These are
classified as internal inconsistencies within the standard or external inconsistencies
with other standards.
Scope arguments - arguments suggesting that the scope of the standard is too narrow
or too wide or the standard is not appropriate.
Outcome arguments - arguments focusing on the impact of the standard on external
users of financial statements (such as investors) or on internal operational decisions.
Due process arguments - arguments focusing on due process, rather than the content
of the standard.
Other arguments - arguments not falling in one of the above categories.
Panel B: Coding Hierarchy N
Population IAS, IFRS Issued 26
Sample Text Dissenting Opinion 25
Unit of Analysis Dissenting Issue 56
Themes Dissenting Arguments 218
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TABLE 2 Summary of Dissenting Arguments
N
IASB
per DO
%
N
FASB
Per DO
%
Conceptual 127 5.08 58.0% 240 4.14 59.0%
Logic 43 1.72 19.6% 72 1.24 17.7%
Scope 17 0.68 7.8% 28 0.48 6.8%
Outcome 20 0.80 9.1% 27 0.47 6.7%
Due process 4 0.16 1.8% 21 0.36 5.1%
Other 8 0.32 3.7% 19 0.33 4.7%
Total 219 8.76 100.0% 407 7.02 100.0%
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TABLE 3 Conceptual Arguments
N
IASB
per DO
%
N
FASB
Per DO
%
Panel A: Framework Qualitative:
Benefit > costs 7 0.28 5.5% 19 0.33 8.0%
Understandbility 2 0.08 1.6% 12 0.21 5.1%
Decision usefulness 15 0.60 11.8% 15 0.26 6.3%
Relevance 10 0.40 7.9% 19 0.33 8.0%
Predictive value 0 1 0.02 0.5%
Feedback value 0 0
Timeliness 1 0.04 0.8% 0
Comparability 19 0.76 15.0% 41 0.71 17.1%
Reliability 6 0.24 4.7% 5 0.09 2.2%
Verifiability 0 5 0.09 2.2%
Neutrality 3 0.12 2.4% 2 0.03 0.7%
Faithful representation 16 0.64 12.6% 35 0.60 14.5%
Materiality 0 0
Completeness 0 1 0.02 0.5%
Total framework qualitative 79 3.16 62.2% 155 2.67 64.5%
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TABLE 3 Conceptual Arguments (continued)
N
IASB
per DO
%
N
FASB
Per
DO
%
Panel B: Framework - Other:
General reference 6 0.24 4.7% 13 0.22 5.3%
Elements of the financial
statements 9 0.36 7.1% 9 0.16 3.9%
Total framework-other 15 0.60 11.8% 22 0.38 9.2%
Panel C: Non-framework:
Accounting objectives 7 0.28 5.5% 9 0.16 3.9%
Complexity 6 0.24 4.7% 10 0.17 4.1%
Conservatism 0
2 0.03 0.7%
Conventional practice 2 0.08 1.6% 9 0.16 3.9%
Disclosure is not a substitute for
proper accounting 1 0.04 0.8% 2 0.03 0.7%
Duality 0
1 0.02 0.5%
Management intent 7 0.28 5.5% 3 0.05 1.2%
Matching 0
1 0.02 0.5%
Matching - Fair value 1 0.04 0.8%
Objectivity/subjectivity 1 0.04 0.8% 6 0.10 2.4%
Other 2 0.08 1.6% 12 0.21 5.1%
Practical difficulties 3 0.12 2.4% 5 0.09 2.2%
Risks & Rewards 1 0.04 0.8%
Transparency 1 0.04 0.8% 1 0.02 0.5%
Uniformity 1 0.04 0.8% 2 0.03 0.7%
Total non-framework 33 1.32 26.1% 63 1.09 26.3%
Total conceptual arguments 127 5.08 100.0% 240 4.14 100.0%
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TABLE 4 Logic Arguments
N
IASB
per DO
%
N FASB
Per DO
%
External consistency 22 0.88 51.2% 35 0.60 48.4%
Internal consistency 8 0.32 18.6% 19 0.33 26.6%
Lack of logic 13 0.52 30.2% 18 0.31 25.0%
Total logic arguments 43 1.72 100.0% 72 1.24 100.0%
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TABLE 5 Scope Arguments
N
IASB
per DO
%
N
FASB
Per DO
%
Narrow 5 0.20 29.4% 4 0.07 14.6%
Wide 2 0.08 11.8% 6 0.10 20.8%
Not appropriate 2 0.08 11.8% 12 0.21 43.8%
Complete conceptual framework project 0 - 3 0.05 10.4%
Complete other projects 8 0.32 47.1% 3 0.05 10.4%
Total Scope Arguments 17 0.68 100.0% 28 0.48 100.0%
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TABLE 6 Outcome Arguments
N
IASB
per DO
%
N
FASB
Per DO
%
Bad accounting outcome 2 0.08 10.0% 9 0.16 34.0%
Earnings Management 6 0.24 30.0% 2 0.03 6.4%
Economic effects 0 4 0.07 14.9%
No Improvement 9 0.36 45.0% 3 0.05 10.6%
Public interest 1 0.04 5.0% 0
Valuation 0 1 0.02 4.3%
Volatility 2 0.08 10.0% 8 0.14 29.8%
Total outcome arguments 20 0.80 100.0% 27 0.47 100.0%
25
TABLE 7 Due Process Arguments
N
IASB
per DO
%
N
FASB
Per DO
%
Due Process 3 0.12 75.0% 14 0.24 66.7%
Transitional 1 0.04 25.0% 7 0.12 33.3%
Total 4 0.16 100.0% 21 0.36 100.0%
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TABLE 8 Other Arguments
N
IASB
per DO
%
N
FASB
Per DO
%
Evidence-based standards 0 4 0.07 21.2%
Standard setting objectives 8 0.32 100.0% 13 0.22 66.7%
Personal Belief 0 2 0.03 9.1%
Total other arguments 8 0.32 100.0% 19 0.33 100.0%
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APPENDIX A Coding Scheme for Dissenting Arguments
Category Coding Theme Description/ Terminology
Panel A: Conceptual Arguments
Framework
(qualitative
characteristics)
Benefit > costs
Cost-benefit
Data continuity
Lack of significance
Understandability Understandability
Decision usefulness
Decision usefulness
Informativeness
Obscures information
Meaningful
Useful
Relevance “Relevance”
“Irrelevance”
Predictive value Predictive value
Feedback value Feedback value
Timeliness Timeliness
Comparability (and
consistency)
Comparability – agree/ disagree
Inconsistency
Like with like transactions
Like with like entities
Reliability “Reliability”
Verifiability Verifiability
Neutrality
Neutrality
Evenhandedness
Inequity
Faithful representation
Faithful representation
Fact, economic reality
Accounting fiction
Misleading
Economic substance
Substance over form
Nature and circumstances
Underlying circumstances
Materiality Materiality
Completeness Completeness/ incompleteness
28
Category Coding Theme Description/ Terminology
Framework
(other)
General reference Conceptual framework reference
Objective of the conceptual framework
Definitions of elements of
the financial statements
Definitions of assets, liabilities, etc
Risks & rewards Risks
Non-Framework
Accounting Objectives
Fails to achieve objectives
Objective of accounting
Objective of financial reporting
Objective of financial standards
Objective of the standard
Complexity Complexity
Conservatism Conservatism
Prudent reporting
Conventional Practice Conventional Practice
Disclosure is not a substitute
for proper accounting
Disclosure is not a substitute for proper
accounting
Duality Duality – matching across entities
Management intention Management intention
Matching Matching
Matching – Fair Value Fair value matching
Objectivity/subjectivity Objectivity
Subjectivity
Practical difficulties
Practical difficulties
Unworkable
Unfeasible
Other
Realization
Additivity
Fair Value
Symmetry
Capital Maintenance
Comprehensive Income
Transparency Transparency
Uniformity Single method
Uniformity
29
Category Coding Theme Description/ Terminology
Panel B: Logic Arguments
Consistency
External consistency
Consistency external
External inconsistency
Inconsistency in treatment between this
standard and another standard (or similar)
Internal consistency
Consistency internal
Inconsistency between paragraphs in the
standard
Lack of logic
Illogical
Illogical
Unsound
Irrational
Lack of conceptual basis Lack of conceptual basis
Arbitrary Arbitrary
Arbitrary rules
Adequacy of other
provisions
Adequacy of other provisions
Lack of internal logic
Lack of logic
Lack of internal logic
Incompatible premises
Lack of reasoning
Lack of reasoning
Unjustified
Fundamentally defective
30
Category Coding Theme Description/ Terminology
Panel C: Outcome Arguments
Internal Internal Impact Internal impact
External
Bad accounting outcome Bad accounting outcome
Earnings Management Earnings Management
Economic effects Economic effects
No Improvement
Lack of improvement
No improvement
Does not use best available information
Offsetting Offsetting
Public interest Public interest
National economic policy issue
Valuation Valuation
Volatility
Fluctuations
Volatility
Under-statements
Over-statements
31
Category Coding Theme Description/ Terminology
Panel D: Scope Arguments
Narrow Narrow
Narrowing advocated by standard
Objection to a provision that narrows scope
Objection to exemption, special provisions
Should have addressed
Insufficient guidance
Wide Wide
Widening advocated by standard
Objection to a provision that widens scope
Objection to inclusion
Should include additional exception
Objection to broader application
Objection to inclusion
Not Applicable
Not Appropriate
Inappropriate
Importance of the issue
Provision advocated by standard
Objection to a provision applying
Futility
Lack of importance of the issue
Urgency/lack of urgency
Complete conceptual
framework project first
Conceptual framework – complete project
first
Complete other projects first Complete other projects first
Guidance not standard
required
Guidance not standard required
32
Category Coding Theme Description/ Terminology
Panel E: Other Arguments
Evidence-based
standards Evidence-based standards
Empirical argument
Examples
Lack of empirical evidence
Lack of practical requirement
Standard setting
objectives
FASB Board’s and
Accounting Profession’s
Objectives
Board’s responsibilities
Credibility
Judgment by Board
Leadership in standard setting
Loss of initiative
Perceived threat to standard-setting
Precedent-setting departure
Professionalism
Visibility
Personal Belief Personal Belief Personal belief
Panel F: Due Process Arguments
Due Process Due Process Due Process
No Public Submission
Transitional Transitional Objection related to transitional provisions