UK: Supreme Court to hand down VTB Capital judgment next week

The Supreme Court has announced that it will hand down its judgment in VTB Capital plc (Appellant) v Nutritek International Corp and others (Respondents) next Wednesday. One of the issues before the court, as explained in the court's summary, was this: if a person uses a puppet company to enter a contract with a third party in order to perpetrate fraud on that third party, can the court pierce the corporate veil and treat that person as a party to the contract? The Court of Appeal held that this could not be done: see [2012] EWCA Civ 808.

UK: FRC consults on implementation of several Sharman Inquiry recommendations

The Financial Reporting Council has published a consultation paper setting out proposed revisions to its guidance on going concern and to the International Standards on Auditing (UK and Ireland): see here (pdf). The revisions follow recommendations made in the final report of the Sharman Panel of Inquiry that was published last year (see here, pdf).

UK: England and Wales: fiduciaries, secret profits and the constructive trust

Earlier this week the Court of Appeal gave judgment in FHR European Ventures LLP v Mankarious & Ors [2013] EWCA Civ 17 and in doing so revisited its earlier (and controversial) decision in Sinclair Investments (UK) Ltd v Versailles Trade Finance Ltd [2011] EWCA Civ 347. A summary of the decision has been provided by the ICLR - see here - the headnote from which reads: "Where a fiduciary, having been involved in advising a purchaser as to the purchase of a hotel, was later found to have benefited by way of a secret commission, it was not necessary, in order to found a constructive trust by reference to the 'loss of opportunity' class of case, to identify some form of beneficial ownership of the opportunity itself."

This headnote does not, however, capture much of the controversy and debate that has arisen following Sinclair in England and elsewhere. The Chancellor (Lord Justice Etherton), in his judgment, stated that the facts of the case highlighted the difficulties with the analysis in Sinclair which had made the law more complex and uncertain. If Sinclair correctly represented the law, and greater coherency and simplicity were required, then in the Chancellor's view it was necessary to revisit many longstanding decisions and to provide an overhaul of the entire area of the law of constructive trusts. If that was a task for the courts (rather than Parliament) then it was one for the Supreme Court, which could consider, amongst other things, whether Sinclair was right to decide that Lister & Co v Stubbs (1890) 45 ChD 1 was to be preferred to AG for Hong Kong v Reid [1994] AC 324. In this regard the Chancellor identified several important questions of policy including the ability to strip the fiduciary of all benefits, the importance attached to the protection of those to whom fiduciary duties are owed, and the position of other creditors on the fiduciary's insolvency who may be prejudiced by a constructive trust or proprietary relief in favour of the fiduciary's principal.

Singapore: a new framework for financial holding companies

Last year the Monetary Authority of Singapore published for comment a draft of the Financial Holdings Bill, following an earlier consultation: see here (pdf). The purpose of the Bill is to introduce a new regulatory framework for financial holding companies (i.e., companies that have a bank or an insurance company as a subsidiary but which do not undertake such activities or other commercial activities). This week MAS a feedback statement containing its responses to the matters raised by those responding to the consultation: see here (pdf).

UK: Supreme Court appeal in Petrodel case - seven justices to hear appeal

Last October, as noted here, the Court of Appeal gave judgment in Petrodel Resources Ltd v Prest [2012] EWCA Civ 1395, [2012] WLR (D) 296. The majority provided a strong endorsement of the company's separate legal personality and its application in family proceedings. Indeed, Rimer LJ stated: "... the separate corporate identity of a company is a fact of legal life that all courts are required to recognise and respect, whatever jurisdiction they are exercising".

Permission to appeal was granted and earlier this year the Supreme Court announced that a panel of five justices would hear the appeal (Lady Hale and Lords Neuberger, Walker, Mance and Wilson). This has changed: seven justices will now hear the appeal, the original panel being joined by Lords Sumption and Clarke (the criteria used to determine if a panel of more than five justices should hear an appeal are available here). Three of the justices (Lords Neuberger, Mance and Wilson) heard argument last year in another case concerning the corporate veil, VTB Capital plc v Nutritek International Corp, the judgment for which is expected within the next couple of months (the hand-down date will be published here).

Note: a copy of the first instance Petrodel decision has only recently been added to the BAILII database: see here.

Update (31 January 2013) - the VTB judgment is being handed down on 6 Feb: see here.

Europe: establishing the single supervisory mechanism

Vítor Constâncio, the vice president of the European Central Bank, delivered a speech yesterday concerning the single supervisory mechanism: see here. After explaining the reasons for introducing the SSM, he outlined how supervision by the European Central Bank of banks in participating countries would operate. He also explained, in the context of the ECB's macro-prudential role, that political agreement was expected soon in respect of the CRD IV.

UK: Tribunal upholds FSA finding of market abuse for 'layering'

The Upper Tribunal Tax and Chancery Chamber has upheld the decision of the Financial Services Authority to fine a Canadian company £ 8 million in respect of "layering" that was found to be market abuse within section 118(5) of the Financial Services and Markets Act 2000: see here (pdf). The FSA's original decision notice, which provides an explanation of "layering", is available here (pdf). The FSA states, in a press release noting the Tribunal decision, that £ 8 million this is the largest fine the FSA has imposed for this particular type of market abuse.

Financial Stability Board meeting in Zurich

The Financial Stability Board met yesterday in Zurich. An overview of the meeting is available here (pdf). The report notes that significant work remains to be done by FSB members with regard to the reform of regimes for the resolution of failing institutions. It is also noted that the FSB's peer review report on risk governance of financial institutions will be published next month and that later this week will see the publication of responses to the FSB's shadow banking consultation (here, pdf).

Update (30 January 2013): the shadow banking responses are available here.

Europe: Eurosystem responds to banking structure proposals

A response from the Eurosystem (the European Central Bank and the national central banks of the Member States whose currency is the euro) regarding the recommendations of the High-level Expert Group on reforming the structure of the EU banking sector has been published: see here (pdf). Amongst other things, the Eurosystem supports the separation of banks' deposit-taking activities from other higher risk activities.

Canada: OSFI publishes revised Guideline on Corporate Governance

The Office of the Superintendent of Financial Institutions Canada (OSFI) has published a revised version of its Guideline on Corporate Governance: see here (pdf). The Guideline applies to federally regulated financial institutions and was first issued in 2003. Further background information is available here.

EFTA Court finds no breach by Iceland under deposit guarantee Directive

The EFTA Court delivered its opinion today in EFTA Surveillance Authority v Iceland (Case E-16/11): see here (pdf). The court held that Iceland did not breach its obligations under Directive 94/19/EC on deposit-guarantee schemes (as it then stood) when it failed to ensure the payment of compensation to depositors in the UK and the Netherlands within the required time limits following the collapse of Icesave. A press summary of the decision is available here (pdf).

Europe: women on the boards of listed companies

The European Commission reports that the proportion of women on publicly listed companies in Europe is now 15.8%: see here. This proportion has increased in the past year in all Member States with the exception of Ireland, Poland and Bulgaria.

UK: England and Wales: anonymity order refused in LIBOR manipulation damages case

Yesterday, in Graiseley Properties Ltd v Barclays Bank Plc (Rev 1) [2013] EWHC 67 (Comm), the High Court refused to grant anonymity during the interlocutory stages of the case to individuals implicated in Barclays' manipulation of LIBOR. The case is widely reported as the first before the English courts in which a party is seeking damages in connection with the manipulation of LIBOR, the argument being based on a claim of fraudulent misrepresentation in respect of the independence of the LIBOR benchmark (for further information see [2012] EWHC 3093 (Comm)).

The trial judge concluded that to grant an anonymity order would be an affront to the principle of open justice and would potentially damage public confidence in the administration of justice. It is interesting to note that an argument linked to the company's separate legal personality was raised in the course of argument. Lord Pannick QC, acting on behalf of those seeking anonymity, drew a distinction between cases where those seeking anonymity were central to the case (and where the courts had refused to grant anonymity orders) and the present case where the individuals' involvement was argued to be incidental because the defendant was Barclays. This distinction was rejected by the trial judge: "I can see no principled reason for drawing that distinction and, in any event, in relation to the individuals who were involved in manipulating LIBOR, the point made is a somewhat doubtful one. Since a corporate entity can only act through its human agents, the identity of those agents is certainly an important aspect of the case" (at para. [36]).

UK: England and Wales: public company re-registration as a private company - entitlement to object under section 98 of the Companies Act 2006

Section 97 of the Companies Act 2006 sets out the procedure to follow where a public company wishes to re-register as a private company and this includes the passing of a special resolution. Where a special resolution has been passed, section 98(1) provides that the "holders of not less in the aggregate than 5% in nominal value of the company's issued share capital or any class of the company's issued share capital" may seek an order of the court cancelling the resolution. Entitlement to seek an order under section 98 was recently considered by the High Court in Eckerle v Wickeder Westfalenstahl GmbH [2013] EWHC 68 (Ch). A summary of the decision has been provided by the ICLR (see here), the headnote of which reads: "The holders of dematerialised shares in a public company were not entitled to the same protection under section 98 of the Companies Act 2006 as registered minority shareholders".

Europe: EBA publishes risk assessment of European banking system

The European Banking Association has published its latest risk assessment of the European banking system: see here (pdf). The report notes, amongst other things, that for most banks the macroeconomic environment remains fragile. The case is also made for further supervisory action to reduce uncertainty with regard to the reliability of banks' reported asset values (an issue that has received the attention of the UK's interim Financial Policy Committee: see here, pdf).

UK: The Financial Services Act 2012 - first Commencement Order made

The first Commencement Order to be made under the Financial Services Act 2012 - the Financial Services Act 2012 (Commencement No. 1) Order 2013 - was made yesterday by the Treasury: see here. The Order brings into force today certain provisions of the 2012 Act and identifies those that will come into force on 19 February: see here. The 2012 Act introduces a new financial regulatory structure in the United Kingdom, about which see here.

Europe: 'one-share, one-vote'

The Financial Times newspaper reports, in an article titled "Brussels aims to reward investor loyalty", that the EU internal market commissioner, Michel Barnier, is "preparing to field views on potentially revising the 'one-share one-vote' principle applied by the bulk of EU companies" in the context of consultation proposals on how to promote sustainable investment in the economy: see here. Several years ago the subject of 'one-share, one-vote' was the subject of work by the Commission: see here.

UK: England and Wales: legal advice privilege, tax law and accountants

The Supreme Court gave judgment earlier today in R (on the application of Prudential plc and another) (Appellants) v Special Commissioner of Income Tax and another (Respondents) [2013] UKSC 1 and held (by a 5:2 majority) that legal advice privilege at common law apply did not apply where accountants gave advice in respect of tax law. A copy of the judgment is available here or here (pdf). A summary of the decision is available here (pdf) and also in the below video recording from the Supreme Court in which Lord Neuberger delivers the court's decision.

Europe: Financial transaction taxation - EcoFin approves enhanced cooperation by eleven Member States

The Economic and Financial Affairs Council has, agreed (by a qualified majority: The Czech Republic, Luxembourg, Malta and the United Kingdom abstaining) to permit eleven Member States (Belgium, Germany, Estonia, Greece, Spain, France, Italy, Austria, Portugal, Slovenia and Slovakia) to begin enhanced cooperation in respect of the introduction of a financial transaction tax: see here (pdf). Further background information is available here.

UK: stewardship prominent in FRC consultation on draft plan and budget

The Financial Reporting Council has published, for consultation, a draft plan and budget for 2013/14: see here (pdf). An area on which the FRC proposes to concentrate is stewardship. In this regard, the FRC notes that "... concept of stewardship is not universally accepted ... it is notable that stewardship is not explicitly and prominently positioned in the International Financial Reporting Standards (IFRS) conceptual framework."

UK: Competition Commission statutory audit market services inquiry - provisional findings now due next month

The Competition Commission has updated its statutory audit market services inquiry timetable: see here (pdf). The notification of provisional findings and (if required) possible remedies, originally timetabled for this month, will now take place in mid February.

Spain: CNMV publishes corporate governance report

Comisión Nacional del Mercado de Valores, the securities market regulator, has recently published its annual review of listed companies' corporate governance statements: see here (pdf). A summary of the findings is available in Spanish here (pdf). Earlier reports, in Spanish and English, are available here.

Germany: the Financial Stability Act

BaFin, the Federal Financial Supervisory Authority, has provided a summary (in English) of the Financial Stability Act (Gesetz zur Überwachung der Finanzstabilität – FinStabG) and its provisions, some of which came into force earlier this month: see here. Amongst other things, the new Act creates a German Financial Stability Committee with members drawn from the Federal Ministry of Finance, the Bundesbank and BaFin.

The German legislation (and that with a similar purpose being adopted in the United Kingdom, Belgium and the Czech Republic) is considered in the first paper to be published this year in the legal working paper series of the European Central Bank: see here (pdf). Note also that the European Systemic Risk Board published last year a recommendation on the macro-prudential mandate of national authorities (ESRB/2011/3, OJ 2012/C 41/01).

Europe: credit rating agencies and credit ratings - new rules approved by Parliament

The European Parliament has approved new rules regarding credit rating agencies and the use of credit ratings: see here. FAQs are available here and further background information is available here.

France: AMF's annual report on corporate governance and compensation

The most recent edition of AMF's financial regulation newsletter, available in English here (pdf), contains a short summary of the regulator's ninth annual report on corporate governance and compensation (published last October and available, in French, here (pdf)). It is reported:"... AMF considered the question of adopting a new approach to drawing up corporate governance codes and expressed its disappointment that professional associations had again paid scant attention to the subjects proposed for further discussion."

Nigeria: Steering Committee formed to develop national corporate governance code

The Federal Government has announced the creation of a steering committee to develop a national code of corporate governance. Further information is available on the recently launched The Corporate Prof blog: see here.

UK: registration of company charges - update on new regime

Companies House has provided further information about the introduction of the new system for the registration of company charges due to be introduced in April this year: see here. The changes will be brought about by the Companies Act 2006 (Amendment of Part 25) Regulations 2013, making changes to Part 25 ("Company charges") of the Companies Act 2006.

Cayman Islands: Monetary Authority corporate governance consultation

The Cayman Islands Monetary Authority has published a consultation paper setting out various corporate governance proposals, including (belatedly many will argue) the introduction of greater disclosure in respect of regulated entities (what is described as 'high level information' will be required): see here. It is also proposed to subject to greater regulation those individuals acting as directors of six or more Cayman Islands registered entities. A very brief overview of the proposals is available in the letter accompanying the consultation paper (here, pdf). Unfortunately a copy of the consultation paper is not currently available on Authority's website (a link is provided on the Authority's website but at the time of this posting it was incorrectly linked to another document).

Update (19 January 2013): the links are now working. A copy of the consultation paper is available here (pdf).

Qatar: draft companies legislation published for consultation

The Ministry of Business and Trade has published for consultation draft companies legislation: see here. A copy of the draft, in Arabic, is available here (pdf) and an explanatory note (also in Arabic) is available here (pdf).

UK: England and Wales: tax law, accountants and legal professional privilege

The Supreme Court has announced that it will hand down its judgment next week in R (on the application of Prudential plc and another) (Appellants) v Special Commissioner of Income Tax and another (Respondents). At issue was whether, at common law, legal professional privilege applied to communications between a client and an accountant seeking and giving legal advice on tax law. The Court of Appeal unanimously held that it did not apply (see [2010] EWCA Civ 1094). For some further background information see here.

UK: Treasury consultation on transposition of the AIFM directive

HM Treasury has published the first of two consultation papers concerning the UK's transposition of the Alternative Investment Fund Managers Directive (2011/61/EU), which will require, amongst other things the authorisation of certain investment managers of hedge funds, private equity funds and investment companies: see here (pdf). The first paper seeks views on various policy decisions that the Government is required to make (matters of scope for example) and includes draft Regulations.

The Treasury's paper should be viewed alongside the related work being undertaken by the Financial Services Authority, which published the first of its two planned consultation papers last November (see here, pdf). Note, too, that last month the European Commission adopted a Delegated Regulation supplementing the AIFM Directive and concerning exemptions, general operating conditions, depositaries, leverage, transparency and supervision: see here (pdf). Further background information is available here.

Kenya: Committee to review corporate governance standards

The Capital Markets Authority has established a committee the function of which will be, amongst other things, to review the corporate governance standards for listed companies including Kenya's Guidelines to Corporate Governance Practices by Listed Companies (2002): see here.

UK: FPC power to supplement capital requirements - draft policy statement published

Section 4 of the Financial Services Act 2012 inserts new Part 1A into the Bank of England Act 1998. Amongst the new provisions are those concerning the Financial Policy Committee, its composition, objectives and powers. The FPC will have the power to give directions to the Financial Conduct Authority and Prudential Regulation Authority requiring them to exercise their functions to ensure the implementation by a specific class of regulated person of macro-prudential measures (see section 9H). Section 9M requires the FPC, in respect of each macro-prudential measure, to prepare and maintain a written statement of the general policy that it proposes to follow in relation to the exercise of its power to give directions under section 9H. In this regard, the interim Financial Policy Committee yesterday published a draft policy statement concerning the power that the FPC will have under the new financial regulatory framework to supplement banks' capital requirements through the use of counter cyclical buffers (CCB) and sectoral capital requirements (SCR): see here (pdf). The paper describes the purpose of the CCB and SCR tools, their fit within the regulatory framework, to whom they will apply and when.

Europe: Commission begins consultation on cross-border transfer of registered office

The European Commission has published a questionnaire seeking views on the costs faced by companies transferring their registered office: see here (pdf). Further information, including copies of the questionnaire in other languages, is available here.

UK: FTSE100 chief executive remuneration - High Pay Centre report and recommendations

The High Pay Centre has today published a report titled Paid to Perform? What do we want our business leaders to achieve?: see here (pdf). The report presents an analysis of the information within the annual reports of FTSE100 companies with regard to the performance measures used for chief executives and makes various recommendations including the requirement that at least fifty per cent of performance related pay should be linked to non-financial metrics.

The report found that the remuneration package for every chief executive was predominantly calculated using financial performance measures, with total shareholder return being one of the most popular measures. Thirty-eight companies stated that they assessed their chief executive's performance with regard to non-financial factors. Companies that had experienced recent serious reputational damage - such as BP and Barclays - had the largest proportion of non-financial measures linked to their chief executive's long-term incentive plan.

Europe: Euribor and benchmark rate setting

The European Securities and Markets Authority and the European Banking Authority have published the results of their joint work on Euribor, including proposed principles for the process by which benchmark rates are set in the European Union. Significant weaknesses are identified with regard to the governance of the Euribor rate setting process (see here, pdf) and recommendations for improvement are made (here, pdf). The proposed principles for the setting of benchmarks, published for consultation, are available here (pdf). Recommendations have also been published regarding the supervision of activities relating to banks' participation in the Euribor panel (here, pdf).

It's also worth noting that the International Organisation of Securities Commissions has recently published a consultation report concerning financial benchmarks: see here (pdf).

BCBS publishes Principles for Effective Risk Data Aggregation and Risk Reporting

The Basel Committee on Banking Supervision has published Principles for effective risk data aggregation and risk reporting, the purpose of which is to strengthen banks’ risk data aggregation capabilities and internal risk reporting practices: see here (pdf). There are 14 principles in total and the first one provides that a bank's data aggregation capabilities and risk reporting practices should be subject to strong governance arrangements consistent with the Basel Committee's other principles and guidance (e.g., Principles for Enhancing Corporate Governance, October 2010).

UK: update on revised guidance from the Financial Reporting Council

Governance and Compliance reports that the Financial Reporting Council will be publishing revised going-concern guidance this month and that its revised internal control guidance (formerly known as the Turnbull guidance) will be published in the second quarter of this year: see here.

Singapore: MAS consults on corporate governance regulations and guidelines for insurers

The Monetary Authority of Singapore has published for consultation draft corporate governance regulations and guidelines for insurers: see here (pdf).

Guernsey: revising the Companies (Guernsey) Law 2008

Legislation to amend the Companies (Guernsey) Law 2008 is expected this year following the approval last year by the States of Deliberation (Parliament) of revisions proposed by the Commerce and Employment Department. An overview of the changes is available in the accompanying Billet d'État (see here, from p. 2163, pdf) and Hansard, the record of debate, is available here (pdf).

India: SEBI publishes consultation paper on corporate governance norms

The Securities and Exchange Board has published a consultation paper seeking views on the governance requirements for listed companies: see here (pdf). The paper is published against the background of the recent passing of the Companies Bill 2012 by the Lok Sabha and, a few months earlier, the publication of the Godrej Committee's guiding principles of corporate governance (see here, pdf). The paper identifies additional rules and provisions that go beyond those in the Bill. For example, views are sought on whether certain companies should be required to have a 'small shareholder director' (i.e., a director appointed by the company's smaller shareholders) and whether shareholder approval should be required for directors' remuneration above a certain limit.

Basel III - approval for revised liquidity standards

The oversight body for the Basel Committee on Banking Supervision - the Group of Governors and Heads of Supervision - met yesterday and agreed the Committee's revised minimum standard for the Liquidity Coverage Ratio (LCR) within Basel III: see here.  The agreed changes to the LCR are available here (pdf) and a summary of the LCR is available here (pdf). A revised timetable for the introduction of the LCR was also agreed: the LCR will come into full effect in 2019.

UK: the gender diversity of private company boards

An article published in yesterday's Observer newspaper, and available here, referred to research regarding the gender diversity of the largest UK private companies. According to the report: "... out of Britain's top 100 private companies, only 64 ... publish the composition of their boards. Of those, 73% have all-male teams of executive directors, 51% have only male non-executive directors and 56% possess all-male boards".

UK: suspected corporate manslaughter cases referred to the CPS

The Attorney General was recently asked this question in Parliament: "... how many cases for potential prosecution of offences under the Corporate Manslaughter and Corporate Homicide Act 2007 have been referred to the Crown Prosecution Service by (a) police forces and (b) the Health and Safety Executive since the commencement of the Act?". Here is the answer that was provided shortly before Christmas (as recorded in Hansard):

The Crown Prosecution Service (CPS) has four Casework Divisions, one of which is the Special Crime and Counter Terrorism Division (SCCTD). Cases involving suspected corporate manslaughter are referred to the Special Crime unit within SCCTD, unless the suspect is an unincorporated partnership, as these cases will be referred to a Complex Casework Unit. The number of cases referred to SCCTD and recorded as being “corporate manslaughter” since the commencement of the Act is 141. The CPS does not hold this data broken down by referring agency. The Corporate Manslaughter and Corporate Homicide Act 2007 does not apply to pre-Act deaths, thus some cases may have been recorded as gross negligence manslaughter rather than corporate manslaughter. The CPS figures are based on a single categorisation of the case type and so, some cases that include a corporate manslaughter element will not necessarily be recorded as a case of that type."

UK: review of insolvency practitioner fees

Shortly before Christmas the Government published the terms of reference for a review of insolvency practitioner fees to be led by Professor Elaine Kempson of Bristol University: see here. The purpose of the review was explained as follows: "... to assess whether further changes need to be made to provide confidence to creditors that IP fees are fair and commensurate with work done for the benefit of creditors. It is also intended to assess whether further changes should be made to improve the speed and amount of returns for unsecured creditors, without impairing the provision of credit to business or consumers".

UK: Supreme Court to hear Petrodel appeal in March

Last October, as noted here, the Court of Appeal gave judgment in Petrodel Resources Ltd v Prest [2012] EWCA Civ 1395. The majority provided a strong endorsement of the company's separate legal personality and its application in family proceedings. Indeed, Rimer LJ stated: "... the separate corporate identity of a company is a fact of legal life that all courts are required to recognise and respect, whatever jurisdiction they are exercising". A summary of the decision is available here.

The court's decision provoked controversy and it is not surprising that a relatively prompt appeal hearing before the Supreme Court will take place in a couple of months' time: see here (pdf). The Panel will comprise of Lady Hale and Lords Neuberger, Walker, Mance and Wilson. Three of these justices (Lords Neuberger, Mance and Wilson) heard argument last year in another case concerning the corporate veil, VTB Capital plc v Nutritek International Corp, the judgment for which has not yet been handed down.

India: copy of Companies Bill 2012 as passed by the Lok Sabha

A copy of the Companies Bill 2012, as passed by the Lok Sabha last month, has been published: see here (pdf). Further background information is available here.

UK: Grant Thornton's 2012 corporate governance review

At the end of last month Grant Thornton published the 2012 edition of its annual corporate governance review: see here (pdf). It is noted that just over a half of all FTSE350 companies complied fully with the UK Corporate Governance Code (board and committee composition was the main area of non-compliance). Other findings: more non-financial companies are choosing to have a risk committee; average auditor tenure is 33 years; a quarter of chairmen gave no insight into board governance practices; over 95% of companies introduced the annual re-election of directors.

IASB identifies future priorities including the Conceptual Framework project

The International Accounting Standards Board has published a feedback statement in which its future priorities are explained: see here (pdf). The statement follows a period of consultation which began in July 2011 and identifies five broad themes to emerge from the consultation, including almost unanimous support for the IASB to prioritise work on the recently restarted Conceptual Framework project. In this regard, the IASB has stated that a discussion paper will be published in June this year with the aim of finalising new sections of the Conceptual Framework by September 2015.