Dear Sir or Madam

Please take below my response to the consultation on the future of UK GAAP on public benefit entities, specifically charities.

It is not clear from the consultation whether charities will be caught by the onerous conditions of Tier 1. I would suggest that they should be limited to Tier 2 or Tier 3 only in order to limit any regulatory burden and costs of compliance, which would be prohibitive for medium sized charities, diverting funds away from the real purpose of their existence and also diverting management time/effort/energy into matters of administration rather than for the public benefit. Although I accept that charities are publicly accountable, they are not listed companies, have no shares that are traded, and therefore have no share price that could lose an investor money.

I would suggest a one-stop shop approach for charities is adopted. This can either be achieved through a framework at high level with the detail contained within a SORP or a standard that effectively replaces the SORP that contains all the detail applicable to such entities.

My other comment concerns the timing of the proposals. In order to minimize any cost of converting figures from UK GAAP to IFRS the committee should consider a relatively long lead time that will encompass at least a 2 year cycle. This will allow entities to more easily prepare their first set of account sunder the new method rather than have to pay for costly services to restate figures, including comparatives, into an IFRS compliant state.

Yours sincerely

Daniel Ross

--------------------------------------------------
Daniel Ross, Chief Executive
The Royal College of Pathologists

UK Consultants – have you checked your details on the Workforce Database?

2 Carlton House Terrace London  SW1Y 5AF

T: 020 7451 6789
F: 020 7451 6701
E: daniel.ross@rcpath.org

W: www.rcpath.org

Registered charity (in England & Wales) number 261035