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 of final standards included a discussion of their rationale, responses to comments, and the board’s dissenting opinions. The board also published an annual report. The board and affiliated organizations, headquartered in London, employed about sixty people, including board members, and had an annual budget of about $18 million, provided through contributions from accounting firms (including $1 million from each of the four largest international firms), corporations, central banks, and international organizations. 223

As in the United States and Britain, a self-perpetuating oversight group, the International Accounting Standards Committee Foundation (IASCF), was intended to provide a buffer from political pressures and assure efficient operation. Its trustees chose board members, appointed the board chair, raised operating funds, and reviewed the board’s constitution and procedures every five years. Its constitution provided that its twenty-two-member self-perpetuating “financially knowledgeable” board of trustees be “representative of the world’s capital markets and a diversity of geographical and professional backgrounds.” It called for six representatives from North America, six from Europe, four from the Asia/Pacific region, and others without geographical designation. 224 The foundation’s first chair was Paul Volcker, former head of the United States’ Federal Reserve Board.

Informal public and private networks also supported the board’s work. The EU encouraged the creation of a private-sector technical group (the European Financial Reporting Advisory Group, EFRAG) and formed the Committee of European Securities Regulators (CSER), which quickly established guidelines for member states’ enforcement bodies, including independence and authority to monitor and correct accounts. To reduce the chances that each nation would in effect create its own sta ndards through different interpretations, CESR also established a database of nations’ enforcement decisions and urged national regulators to follow precedents as they were established. 225 The International Federation of Accountants (IFAC) proposed a peer review system for periodically and randomly reviewing the accounts of multinational companies and issued a new standardized audit report form to improve the comparability of accounts. 226 In May of 2004 the SEC and CESR announced that they were increasing their collaborative efforts in order to improve communication about regulatory risks between Europe and the United States and to promote convergence in future securities regulation. 227

Enforcement of accounting standards, however, was left to national regulators. The board remained a private membership organization with no authority to compel nations or companies to adopt its disclosure rules. The public character of its authority rested solely on the endorsement of its processes and standards first and foremost by national governments and then by complex networks of national politicians, regulators, accounting firms, stock exchanges, companies, investors, and other market participants. Enforcement practices varied widely among nations that represented major markets. 228

In 2006, the development of international corporate financial a ccounting standards appeared to be sustainable. Standards had improved markedly over time in scope, accuracy, and use. However, it was not yet clear what degree of harmonization the international board would achieve, whether a critical mass of nations and companies would continue to support the bo ard’s effo rts, a nd how well standards would be enforced by national regulators. Standards for financial derivatives, stock options, and other complex instruments remained controversial. Nations’ capacities to administer and enforce