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C00493 1 (2011-09-08)

handle is hein.gao/gaobadofn0001 and id is 1 raw text is: 

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       Accountability  I ntegrity  Reliability
United States Government Accountability Office
Washington, DC 20548


         September 9, 2011

         The Technical Director
         International Public Sector Accounting Standards Board
         International Federation of Accountants
         277 Wellington Street West
         Toronto Ontario Canada M5V 3H2


         Subject: International Public Sector Accounting Standards Board (IPSASB)
         December 2010, Conceptual Framework for General Purpose Financial Reporting
         by Public Sector Entities Exposure Draft: Role, Authority and Scope; Objectives and
         Users; Qualitative Characteristics; and Reporting Entity

         This letter provides the U.S. Government Accountability Office's (GAO) comments
         on the IPSASB Conceptual Framework for General Purpose Financial Reporting by
         Public Sector Entities Exposure Draft. The Conceptual Framework is an important
         and timely initiative that makes explicit the concepts, definitions and principles that
         the Board will use to develop International Public Sector Accounting Standards
         (IPSASs) or non-authoritative guidance applicable to the preparation and
         presentation of general purpose financial reports. We are supportive of the
         framework, which is consistent with several key concepts articulated in the Federal
         Accounting Standards Advisory Board's Statement of Federal Financial Accounting
         Concepts (SFFAC 1): Objectives of Federal Financial Reporting and seeks to
         provide for application to diverse forms of government and other differences that
         may exist in the jurisdictions that adopt IPSASs.

         We also strongly agree that the Conceptual Framework should not establish
         authoritative requirements for financial reporting by public sector entities that adopt
         IPSASs nor override the requirements of IPSASs. It is our view that a conceptual
         framework is more general than accounting standards and therefore should not
         contain specific authoritative requirements for entities to follow and should provide
         general guidance to the Board itself as it deliberates on specific issues. The
         conceptual framework is also useful to others in understanding accounting and
         financial reports prepared in accordance with the IPSASs. We also support using
         the Conceptual Framework to provide guidance on financial reporting issues that are
         not articulated in the IPSAS or other non-authoritative guidance. Our specific
         comments are discussed below.

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