IESOC Comment 12.14.01

INTERNATIONAL EMPLOYEE STOCK OPTION COALITION December 13, 2001 Sir David Tweedie Chairman, International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Sir David: As trade associations and companies representing a diverse range of industries in the U.S. and abroad, we speak for thousands of organizations that issue employee stock options and millions of workers, many of whom receive stock options. We write in opposition to the conclusions in the IASC/G4+1Discussion Paper on accounting for employee stock options. We urge the IASB to adopt the disclosure-based approach set forth in U.S. Financial Accounting Standards Board’s (FASB) Statement of Financial Accounting Standard No. 123 (SFAS 123). Our organizations have a significant stake in the mission of the International Accounting Standards Board. We are deeply concerned, however, that by electing to take up stock option accounting as one of its first major issues, the IASB raises troubling questions about its future. At a time when stock markets are volatile and business investment is exceedingly weak, we are certain that the G4+1 proposal will unnecessarily regenerate a controversy that the FASB’s disclosure-based approach, embodied in SFAS 123, already resolved. If the IASB continues on this controversial track, the debate on this one issue could endanger the current consensus supporting the IASB. We recognize the increasing ...