CFA Institute Corporate Disclosure Policy Council Financial Accounting Standards Board October 31, 2013 Agenda CFA Institute – − History & Membership Profile − Mission, Strategy & Advocacy Efforts − Understanding Our Valuation Philosophy & Our Position Development (Comprehensive Business Reporting Model) Engaging Effectively with Investors and Users – − Investors & Users – − Who are they? − What drives their financial reporting agenda? − Importance of Reporting Objective & Investor Focus − Communicating with Investors 2 CFA Institute – History & Membership Profile 3 CFA Institute – History (Benjamin Graham) CFA Institute’s history is rooted in: - the views of the father of modern security analysis, Benjamin Graham, who believed in an intrinsic or fundamental valuation approach. - the post depression era reforms of the U.S. Securities Act of 1933 & 1934 which changed the availability & transparency of information to investors. “The analyst who qualifies for the rating will have the obvious advantages of prestige, improved ability to get a job, and the chance for higher pay. In addition, he is likely to develop a more professional attitude towards his work and a keener interest in maintaining and advancing the standards of his calling.” Benjamin Graham, The first edition of the Analysts Journal, 1945 4 CFA Institute – History (Professional Designation for Analysts) – Availability of Information – As more information on companies became available in wake of Depression-era financial reforms the nature of work of analysts was changing from “statistician” to “financial analyst”. – Need for Analysis and Security Selection as a Profession – The “Dean of Wall Street” and proponent of fundamental analysis was first to advocate need for professional certification of analysts. Guided by his urging industry leaders worked to making his idea a reality. More than 20 years were needed for this conversation to come to a fruitful conclusion. – Emergence of CFA Program – CFA Program developed in 1962 (professional organization founded 1947). First exam given in 1963. The certification encompasses values of professional excellence, ethics, respect and building an investment industry that serves the interests of investors and society. Ethics and Professional Standards have always been an important component and are tested at all levels. 5 CFA Institute – History (Organizational Evolution) 1947 1961 National Federation of Financial Analysts Societies (NFFAS) Financial Analysts Federation (FAF) 1962 Institute of Chartered Financial Analysts (ICFA) Name Change 2004 1990 CFA Institute Association for Investment Management & Research (AIMR) Name Change Merger FAF & ICFA 6 1967 New York 1961 Charlottesville 2009 Brussels 2001 London 1997 Hong Kong 7 CFA Institute – Global Membership Growth 111,079 117,161 105,889 101,140 73,960 43,043 17,880 1990 21,330 1995 2000 2005 2010 Data provided in five-year increments from 1990 to 2010. 2011 2012 2013 Annual data. 8 CFA Institute – Global Membership Regional Composition 1.3% 0.7% 10.0% 3.3% 2.0% 12.3% 0.7% 1.0% 1.0% 1.1% 6.6% 4.8% 11.8% 14.7% 15.3% 16.1% 16.7% 12.7% 10.9% 17.5% 18.2% 18.5% 19.1% 12.5% 12.5% 12.4% 12.4% 54.3% 53.1% 51.9% 50.7% 2010 2011 2012 2013 13.5% 87.8% 81.9% Membership Totals: 17,880 Non-US 49.3% 75.4% 63.2% Years: 1990 1.1% 1995 2000 2005 21,330 43,043 73,960 North America (excluding Canada) 101,140 105,889 111,079 117,161 Axis Title Canada Europe, Africa, Middle East Asia Pacific Latin America & Caribbean 9 CFA Institute – Global Candidate Growth 219,642 209,945 212,129 200,113 111,105 70,090 16,390 19,910 1990 1995 2000 2005 2010 Data provided in five-year increments from 1990 to 2010. 2011 2012 2013 Annual Data 10 CFA Institute – Global Candidate Regional Composition 1% 1% 12% 15% 4% 14% 1% 24% 5% 1% 2% 2% 2% 1% 41% 43% 44% 44% 32% 15% 15% 13% Non-US 9% 69% 64% 47% Years: 1993 Candidate Totals: 16,390 74% 19% 22% 21% 21% 21% 8% 8% 8% 8% 27% 26% 25% 24% 38% 1995 2000 2005 2010 2011 2012 2013 19,910 70,090 111,105 200,113 209,945 219,642 212,129 North America (excluding Canada) Europe, Africa, Middle East Latin America & Caribbean Canada Asia Pacific Note: Candidates are classified by address. If classified by passport, Asia Pacific would represent approximately 10% greater portion of candidates. 11 CFA Institute – Occupation & Employer Profile of Global Membership Occupation % of Membership Top Twenty Employers Charterholders Portfolio Managers 22% Bank of America Merrill Lynch 1,564 Research Analyst 15% UBS 1,467 JP Morgan Chase 1,422 Analyst 24% Corporate Financial Analyst 5% Investment Banking Analyst 4% RBC 1,112 Chief Executive Officer 7% HSBC 1,064 Consultant 6% Risk Manager 5% Financial Advisors & Private Bankers 5% Relationship Manager 5% Accountant/Auditor 3% Other 23% Total 100% Wells Fargo 999 Credit Suisse 968 Citigroup 925 Morgan Stanley Smith Barney 910 Deutsche Bank 898 Goldman Sachs 880 BlackRock 800 Barclays 789 TD Bank Financial Group 741 BMO Financial Group 695 PricewaterhouseCoopers 672 FMR Corporation 643 Allianz SE 639 ING Group 538 CIBC World Markets Inc. 531 Top 20 employers represent nearly 17% of all charterholders 12 CFA Institute – Mission, Strategy & Advocacy Efforts 13 CFA Institute – Mission, Strategy & Advocacy Efforts 14 CFA Institute’s Education Objective – CFA Program (Candidate Body of Knowledge) 15 CFA Institute’s Education Objective – CFA Program (Candidate Body of Knowledge) Topic Area Ethical & Professional Standards Level I Level 2 15% 10% Level 3 10% Investment Tools Corporate Finance Economics Financial Reporting and Analysis Quantitative Methods 50% 30%-60% 0% Asset Classes Alternative Investments Derivatives Equity Investments Fixed Income 30% 35%-75% 25%-65% 5% 5%-15% 100% 100% 45%-55% 100% Portfolio Management and Wealth Planning Total 16 CFA Institute’s Education Objective – CFA Program (Pass Rates & Experience Requirements) Exam Pass Rates: June 2012 Actual 10-Year Average Level I* 38% 38% Level II† 42% 43% Level III† 52% 55% * - Level 1 offered in June and December (first December administration was in 2003) † - Levels II and III administered in June only Experience Requirement: 4 Years of Qualifying Work Experience Necessary to be Recommended for Membership. 17 CFA Program – Financial Reporting and Analysis: Accounting Basis Accounting Basis: IFRS with Reference to U.S. GAAP 18 CFA Institute’s Advocacy Objective – Standards & Financial Market Integrity (SFMI) Division Standards & Financial Market Integrity (SFMI) Division Advocacy & investor representation occurs through the SFMI division. Including predecessor organizations, CFA Institute has over 40 years experience advocating for financial market integrity and transparency. SFMI Division (previously known as the CFA Centre for Financial Market Integrity) was formed in 2004 as the policy and research group to address global capital market issues. Capital Markets Policy Financial Reporting Policy Promote fair and open markets, investor protections, and professional standards. Advocate for improved financial reporting so investors receive transparent and consistent information upon which to make investment decisions. Advocate for integrity in the capital markets through high quality corporate governance and shareholder rights. Investment Performance Standards Set and maintain standards for investment performance reporting. Global Investment Performance Standards (GIPS). Standards of Practice Establishes the ethical and professional conduct requirements for CFA charterholders. The team also promotes these principles to the broader investment community through the adoption of voluntary standards and best practice guides for asset management firms and trustees of pensions and endowments. 19 CFA Institute’s Advocacy Objective – Financial Reporting Policy Group Content Advocacy & Outreach Thought Leadership Awareness User Perspectives on IFRS 7 Risk Disclosures Disclosure Framework Media & Press Mentions Articles & Publications , Issue Briefs Webcasts, Podcasts, Blog Posts Presentations/Speaking Engagements Technical Information & Comment Letters Engagement IASB FASB SEC PCAOB IAASB Participation on Advisory Committees & Roundtables CDPC Meetings with Standard Setters Member Surveys 20 CFA Institute’s Advocacy Objective – Financial Reporting Policy Group How Do We Develop Our Positions? Position CFA Institute Staff Corporate Disclosure Policy Council Surveys / Working Groups / Direct Outreach Members 21 CFA Institute’s Advocacy Objective – Financial Reporting Policy Group – Engagement with Members – Member Surveys – We have conducted multiple comprehensive surveys of members’ views on key financial reporting issues (e.g. Fair Value Application, Disclosure Framework, U.S. Adoption of IFRS, Segment Reporting and Financial Statement Presentation). Dedicated Financial Reporting Survey Pool – So as to cast as broad, but as relevant, a net as possible on matters of interest, our survey pool on most financial reporting matters is generally comprised of 15,000 to 20,000 members Member Webcasts – Webcasts to members (e.g. IFRS 9, U.S. Adoption of IFRS, Financial Instruments, IFRS Agenda and Revenue Recognition) Other Member Outreach – Engagement with member societies (e.g. UK, Germany, Canada, France) and specialist working groups (e.g. Insurance Working Group). Broadening Investor Network – Actively expanding investor outreach across key jurisdictions. – Engagement with Other Investors – Ongoing engagement with other investor organizations (e.g. CRUF, CII, EFFAS and Japanese Society of Financial Analysts). – Engagement with Corporate Disclosure Policy Council (CDPC) – CDPC is comprised of 10+ global practicing investment professional and accounting expert members. CDPC provides investor oriented advisory input to our positions. – Engagement with Key Regulatory Bodies – SEC, FASB, EFRAG , European Commission, Financial Stability Board. Center for Audit Quality, IAASB, PCAOB. – Body of Knowledge – Through such engagement we formed a body of knowledge and our positions. 22 CFA Institute’s Advocacy Objective – Financial Reporting Policy Group Myths Realities CFA Institute views are academic or purist in their approach. CFA Institute’s views are grounded in a solid conceptual framework that is documented and has been consistent over time. CFA Institute views will destroy economic value or are not consistent with economic reality. CFA Institute’s views are developed from an economic perspective and seek to appropriately reflect economic events in financial reporting. CFA Institute views are pro-cyclical. Financial reporting seeks to portray events. Simply reflecting values currently being transacted at does not create the transaction price. “Real investors” don’t agree with CFA Institute. Our members are real analysts and investors across the globe (see occupation and geographic slides). Our views are supported by member surveys. We have been consistent and persistent in the pursuit of our solidly and logically grounded financial reporting objectives. CFA Institute supports liquidation accounting. We do not support liquidation accounting. We support information that investors can use to value the enterprise. 23 CFA Institute’s Advocacy Objective – Financial Reporting Policy Group Myths Realities The requests are complex and cost prohibitive. Transactions are complex – and becoming increasing complex. Accounting complexity generally derives from economic complexity. CFA Institute does not compromise. Our approaches are not pragmatic. Our views are meant to portray economic reality. Compromises diminish economic meaning. We have provided the most comprehensive, cohesive and consistent investor framework and feedback to the standard setters over the decades. The information is not possible to obtain. Information is economic and used by management to make decisions. We have seen that when there is a will, there is a way to obtain the information. CFA Institute’s views are U.S. centric. Membership surveys support our views and consistently represent geographic distribution with nearly half of the membership located outside of the U.S. . 24 CFA Institute’s Advocacy Objective – Financial Reporting Policy Group Long History of Commenting On Controversial Financial Reporting Positions Issues We’ve Advocated For Over Time Where We’ve Heard These Comments Before….. 1970s Leases: Advocated reporting of lease obligations on balance sheet. Lessee and lessor accounting should be the same. 1980s Employee Benefit Plans: Advocated transparent reporting of economic position in financial statements (e.g. all liabilities on balance sheet, fair value for assets, elimination of smoothing, better assets & liability disclosures). Cash Flows: Supported separate reporting of operating, investing, and financial cash flows. Advocated for direct cash flow statements. 1990s Debt and Equity Securities: Debt and equity securities should be measured at fair value. Stock Based Compensation: Supported expensing of stock-based compensation. Derivatives: Derivatives should be fully disclosed and accounted for at fair value. 2000s Acquisitions: Supported elimination of pooling of interest method that suppressed economics of acquisitions. …Some Have Come To Pass Over Many Years… 25 CFA Institute – Understanding Our Positions 26 CFA Institute – Understanding Our Positions Financial Reporting in the 1990s and Beyond (1993) States how and why financial reports are used in the analytic process. Articulates what disclosures are essential to analysts, not only their form and content, but also frequency with which they are reported and means of dissemination. Defines separate, but complimentary, roles of financial analysis and financial reporting. 27 CFA Institute – Understanding Our Positions Comprehensive Business Reporting Model (CBRM) (2007) Articulates Financial Reporting Best Practices – Constructed after long period of deliberation and reflection of positions articulated over the years. Based on: Financial Reporting in the 1990s and Beyond (1993) and previous advocacy efforts spanning over several decades Emphasizes Economic Reality – Represents a vision that can be realized if financial reporting improvements are to place greater emphasis on faithfully reflecting economics of reporting companies. Provides Financial Reporting and Disclosure Objectives – Primary objective of financial reporting & disclosure must be to provide all of information that owners of common equity require to evaluate their investments. Develops 12 Core Principles – Articulates principles that should govern financial reporting. Provides a Standard Setting Progress Yardstick – 12 core principles provide measure of progress of ongoing standard setting. 28 Understanding Our Positions – Comprehensive Business Reporting Model Principles 1. Information Needed by Suppliers of Capital The primary financial statements must provide the information needed by equity investors, creditors, and other suppliers of risk capital. 2. Perspective of Equity Investor In financial reporting standard-setting as well as statement preparation, the company must be viewed from the perspective of an investor in the company’s common equity. Equity investors, who bear the greatest risk, need the most information. So when their information needs are satisfied other investors will have received the information they need. 3. Relevance of Fair Value Fair value information is the most relevant information for investment decision-making. 4. Recognition & Disclosure Determined by Relevance Over Reliability Recognition and disclosure must be determined by the relevance of the information to investment decision-making and not based upon measurement reliability alone. 5. Recognition Upon Economic Occurrence of Transaction/Event Transactions and events that affect the company’s economic position must be recognized as they occur in the financial statements. 6. Investor Materiality Threshold Investors’ information requirements must determine the materiality threshold. 29 Understanding Our Positions – Comprehensive Business Reporting Model Principles 7. Neutrality Financial reporting must be neutral. 8. All changes in net assets, including changes in fair values, must be recorded as incurred in a single financial statement, the Statement of Changes in Net Assets Available to Common Shareowners. Statement of Changes in Net Assets Available to Common Shareowners 9. Direct Cash Flow Method The cash flow statement provides information essential to the analysis of a company and must be prepared using the direct method only. 10. Disaggregation Changes affecting each of the financial statements should be reported and explained on a disaggregated basis. 11. Reporting Based on Nature Individual line items should be reported based upon the nature of the items rather than the function for which they are used. 12. Effective Disclosures Disclosures must provide all the additional information investors require to understand the items recognized in the financial statements, their measurement properties, and risk exposures. 30 Understanding Our Positions – Comprehensive Business Reporting Model Criteria for Development of Effective & Useful Disclosures 1. Disclosure Complements Recognition & Measurement Disclosure is not a substitute for recognition and measurement, and recognition and measurement do not eliminate the need for disclosure. 2. Concurrent Development of Recognition, Measurement & Disclosure Standards Standards for recognition and measurement of financial statement items and their related disclosures must be developed concurrently. 3. Disclosure of Judgment & Choices Policy choices, assumptions, judgments, and methods must be fully and clearly disclosed. 4. Disaggregation Disclosures should provide sufficient disaggregated information for investors to be able to fully understand and interpret the summary information in the financial statements. 5. Disclosure of Risks Investors require clear and complete disclosure of a company’s risk exposures, its strategies for managing risks, and the effectiveness of those strategies. 6. Disclosure of Off-Balance Sheet Items Investors must have clear and complete disclosure of all off-balance sheet assets, liabilities, and other financial arrangements and commitments. 7. Disclosure of Intangible Assets Investors require clear and complete information about intangible assets held by a company. 8. Disclosure of Contingencies & Commitments Investors require clear & complete information about a company’s contingencies & commitments. 31 Understanding Our Positions – Comprehensive Business Reporting Model The CBRM attracted widespread attention for our views on: Fair Value Financial Statement Presentation Disaggregation Rollforwards Cohesiveness Direct Method Cash Flow Desire for fair value measurement is connected with appropriate financial statement presentation Fair value and cash flow are both useful measures. Accounting can be cash, fair value or smoothed accounting conventions. We need the fair values of existing assets and liabilities along with a financial statement presentation that transparently reports cash flows using the principles of disaggregation, cohesiveness and rollforwards that facilitate connection of the value and cash flow based measurements across the financial statements. This comes from our belief that such reporting supports all investment valuation methodologies. 32 Understanding Our Positions – Our Views vs. Other Investor Views Information Needs Vary Due to Different Valuation Approaches Intrinsic Value Approach Seeks to determine what a stock is worth. (i.e. price at which it would sell if properly priced in the market.). Relative Value Approach Is concerned with the relative (comparative) valuation of similar enterprises. Promotes smoothening as it enhances comparability. CFA Institute positions are based on an intrinsic value approach. (Benjamin Graham was proponent of the intrinsic value approach). We believe that both approaches are widely used (often in combination). Our views are developed from the perspective of the long equity investor. This is why the CBRM principles focus on value. Investor focus on total return over time leads to importance of market (fair) values. 33 Engaging Effectively with Investors and Users 34 Engaging Effectively with Investors and Users – Who Are They? What Drives Their Financial Reporting Agenda? Ask Questions: When seeking investor or user input on financial reporting topics it is important to ask the following questions: Compensation How is investor user compensated? How do they make money? Conflicts of Interest Does the input received reflect any conflicts of interest? Investment banking relationship Dependence on access to management for client meetings or conferences Is the investor an advocate of good financial reporting for all investors or does investor believe they can exploit the lack of information in the financial statements to seek investment returns (e.g. fair value information on real estate)? What Consequences Exist for Loss in Value? What is the consequence of a loss of investment value? (e.g. loss of value, loss of fees on value, inability to make pensioner payments, loss of customer, etc.). What is the downside risk? Who bears the loss? What Motivates the Input? Does the input reflect an interest in financial reporting or concern over possible economic consequences of new standards? 35 Engaging Effectively with Investors and Users – Who Are They? What Drives Their Financial Reporting Agenda? Ask Questions: When seeking investor or user input on financial reporting topics, it is important to ask the following questions: Type of Organization What type of organization do they work for? (e.g. investment bank, corporation with public filings, etc.) Use of Financial Statements/ Access to Company Management How does the investor/user actually utilize financial statements? What access do they have to company management other than financial statements? Valuation Approach Are they in the business of valuing the enterprise or its securities? What valuation approach, if any, do they use? Are they valuing debt and/or equity? Does the investor/user perceive there is a difference in financial reporting needs based upon the percentage of enterprise acquired (e.g. If acquiring entire enterprise vs. individual/institutional investor)? 36 Engaging Effectively with Investors and Users – Who Are They? What Drives Their Financial Reporting Agenda? Ask Questions: When seeking investor or user input on financial reporting topics it is important to ask the following questions: Type of Investor What asset class do you invest in? What industry do you follow? Are you a passive or active investor? Are you a long-term or short-term investor? Do you invest for maximum return or to fund operations/liabilities? Does The Investor Favor Lack of Transparency in Financial Reporting? Ask why transparency is bad for investors? Volatility When hearing that volatility is bad or non-economic, ask why it is bad or non-economic? Regulatory (Solvency/Liquidity) Information Are there sufficient sources of regulatory/solvency/liquidity information available from sources other than IFRS or U.S. GAAP reporting? Is financial reporting a proxy for appropriate regulatory reporting? Should that be the goal of standard setting? 37 Engaging Effectively with Investors and Users – Who are They? What Drives Their Financial Reporting Agenda? Sell-Side Analysts Buy-Side Investors (Passive) Sell-side analysts are not investors and they do not make investment decisions. These individuals are price-takers ¬ in the business of making detailed valuation decisions. Their work is used as a selling tool by the investment banks or brokerages they work for. They are widely known because of publicly available reports and participation on analyst calls. Heavy emphasis on projecting future earnings. As such, preference is for reduction in volatility. Many work to replicate indexes or tracker funds. They are not users of financial reporting per se. Buy-Side Analysts & Investors (Active) These analysts & investors are in the business of using financial reporting information to estimate values and make investing decisions. May use different approaches (e.g. relative versus fundamental) & hence information needs & desire for comparable information versus value based measurements may be different. Who they work for & the purpose of the investment decision (e.g. seeking alpha or funding liabilities/operations) may vary. Theoretically whether they are valuing equity or debt should be valuing the enterprise, but credit analysts have preference for cash flow/ amortized cost for debt to determine repayment capacity. 38 Engaging Effectively with Investors and Users – Who are They? What Drives Their Financial Reporting Agenda? Hedge Funds/Private Equity Hedge funds & private equity investors attempt to use management or financing skills to improve returns. Tend to utilize a more fundamental/intrinsic value approach. Are compensated based upon returns achieved. May use their skill to exploit asymmetry of information in financial reporting. Pension Plans/Endowments/Foundations Pension plans, endowments, & foundations invest to fund liabilities or operations. Losses may result in inability to fund operations or liabilities as well as reduction of compensation for investment decision-maker. May make asset allocation decisions & delegate investing decisions or may make investing decisions directly. Generally active buy-side analysts & investors (price-makers). Credit Rating Agencies Credit rating agencies do not make investing decisions. Use financial statements and, in some cases nonpublic information furnished by the enterprise, to provide credit ratings. Heavily interested in cash flows & debt repayment ability on debt securities being rated. Don’t do valuations of the enterprise per se. Are compensated by entities to whom they are issuing the rating. Prudential Regulators Prudential regulators are concerned with liquidity and solvency rather than valuation. Have the right to require other information or accounting methods. Basing accounting standards on prudential regulatory needs may result in loss of information to investors & other users of financial statements. 39 Engaging Effectively with Investors and Users – Who are They? What Drives Their Financial Reporting Agenda? Evaluate Answers to Determine Financial Agenda Understanding the answer to these questions will provide insight into the investors/users’ financial reporting agenda and what information is or is not needed and why. Expect Diversity of User Opinions Should Not Lead to Gridlock or Dismissal of Investor Views: Diversity of viewpoints among users is to be expected and should provide impetus for standard setters to understand why differences arise and to seek the most transparent information. Should Not Lead to Opinion Shopping: Risk of opinion shopping increases if standard setters are seeking a single representative view. Consider CFA Institute’s Financial Reporting Agenda Our objective is to provide an unbiased, long-term view as to transparent financial reporting from a long equity position fundamental valuation view. We focus on both the valuation of existing assets and liabilities, the cash flow generating capabilities of the organization and the underlying valuation of the enterprise. We believe that if financial reporting meets the needs of this perspective, then all investors and users financial reporting needs will be addressed. 40 40 Engaging Effectively with Investors and Users – Define Reporting Objectives Importance of Defining Reporting Objective – We believe it is important to define the reporting objective so as to not lose sight of whether the standard setting process serves the needs of most investors. We believe that the standard setting process sometimes loses sight of the reporting objective. Questions to consider: Who is your target audience? − Specialist industry investors or general purpose users of financial statements? − Have you engaged with them to determine whether they agree with the objective & the results What are you trying to communicate? − Cash flow, financial position or operating results? Has the objective been defined in advance? What reporting issue has been identified for correction? Are there clearly defined and conceptually sound reasons for deviating from original reporting objective? Does the information provided by the standard reflect the economics of the underlying transactions? 41 Engaging Effectively with Investors and Users – Develop User Oriented Communication Tailor Communication and Minimize Excessive Accounting Parlance – − Much of standard setting language is accounting parlance investors are not familiar with (e.g. unit of account, assets created with no alternative use, performance obligations at a point in time). − Accounting speak should be mapped to commonly understood terms. Include Practical Illustration of Concepts – Communicate using practical industry specific real world examples. Emphasize Likely Financial Statement Impacts – Highlight impact of accounting standards changes on financial reporting for different industries. Train Staff in Use of Financial Reporting in Analysis of Financial Statements – The standard setting staff needs to understand how analysts and investors use the information contained in financial statements. Better Articulate the Effects of Proposed Standards – − Articulate changes, basis of changes and impact of changes that are proposed across consultative documents (e.g. existing literature, discussion paper, exposure draft and re-exposure draft). − Do not assume investors are familiar with previous accounting literature. Coordinated Communication Necessary to Avoid Burdening Investors – Minimize duplicative communication by standard setting bodies (e.g. IASB, FASB, EFRAG and other national standard setters). 42 Engaging Effectively with Investors and Users – Information Intermediaries & Decision-makers Recognize Different Investor Roles in Security Selection Process − Information intermediaries provide input for investment decisions (e.g. security selection decisions and trading strategy recommendations). − Decision-makers include fund and other portfolio managers who actually decide which securities to buy or sell and when to do so. Investor Organizations Possess Multilingual Capability − Have understanding of investor perspective and investment analytical approaches. − Better capacity to monitor detailed standard-setting and technical accounting development. Investor Organizations are Standard Setting Outreach Partners − Can facilitate communication to and from investors regarding key standard setting developments (e.g. surveys and webcasts). − Are less constrained in speaking out on behalf of investors. − Are well placed to solicit investor input on key financial reporting topics. − Can be potential partners in standard setting research objectives. All Inclusive User Engagement Approach Necessary Important to identify knowledgeable experts across information intermediaries including investor organizations as well as from investment decision-makers. 43
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