From: CLIVE SEXTON [clivesexton@btinternet.com]
Sent: 17 January 2010 12:20
To: UK Gaap
Subject: Public Benefit Entities and International Reporting Standards

I work as a finance manager for a medium sized charity and I would like to make the following comments:

 

I recognise the imperative to standardise accounting standards across international boundaries, and the largest charities operate on a similar global scale to the largest private sector entities.  Charities must be as accountable to stakeholders as are entities in other sectors.
 

Charities differ from commercial entities and public sector entities both in their purpose and in the legal/regulatory framework within which they operate.  This needs to be reflected in their published financial statements, and is done so currently (and in my view very effectively) by the SORP that applies to charities.  This has evolved over the last 10 to 15 years into a document that is widely understood and accepted in the charity sector.

 
We need to find a solution that achieves an acceptable balance between the above two statements.
 
I think that the most straightforward solution would be to retain a separate reporting standard for charities, based on the existing Charities SORP, but incorporating changes (e.g. in asset valuations, recognition of liabilities) that arise from the application of international standards.  The current SORP substantially meets the needs of users, primarily those who work in the charity sector and those who fund charities. 
 
On a point of detail, there is an ongoing debate over the issue of whether or not the time of volunteers should be valued and incorporated in the accounts of charities.  I believe that inclusion of such a figure in the primary statements would be too subjective (e.g. what hourly rate would one apply?).  The current requirement is that the contribution of volunteers should be commented on in the narrative of the Trustees Annual Report, and I would suggest that this be extended to include an estimate of the value of the volunteer contribution in £, with an explanation of how the notional hourly rate was arrived at.
 
I hope that you find these comments helpful.  Please let me know if you would like me to clarify any aspects, or if you would like me to comment in more detail.
 
Kind regards
 
Clive Sexton FCCA DChA


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