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Specific questions raised in the invitation to comment

ACCA agrees with most of the proposals in the consultation document. We have provided answers below to those few consultation questions where we have any comments to make.

The Pension Fund Accounts

ACCA agrees with the approach adopted for accounting for pension fund accounts in the Statement of Accounts of pension fund administering authorities. There is, however, a small error in the proposed paragraph 4.38: the reference should be to �Section 1 Commentary' rather than �Sections 2'.

Q4 Do you agree with the proposed amendments to the Information To Be Disclosed In The Notes To The Accounts? If not, what changes would you make to the proposed amendments?

ACCA questions whether providing the subdivisions of headings in a note to the Authority's Statement of Accounts is necessary as this is intended to be only a summary of the full Pension Fund Report and Accounts. We believe it would be preferable to provide a note saying that detailed breakdowns are provided in the full Pension Fund Accounts. An analysis of Investment Assets held, in the Net Assets Statement, should be provided as this is key information for readers of the authority's accounts. This should be provided on the face of the accounts to avoid the need for notes.

Accounting Standards Developments

Q8 Do you agree that, as required by FRS 21 Events after the Balance Sheet Date, there should be a note to the accounts disclosing the date of authorisation for issue of the financial statements?

We agree with the need to adopt this requirement; however, we believe that the appropriate �authorised for issue date' for a local authority should be the date on which the council agrees the accounts, rather than the date on which the chief financial officer signs the final version of the accounts. This would provide comparability with the private sector, where the date of the board of directors' agreement to the accounts is the date which is used.

Initial Consultation on Options for the Capital Financing Charge (Notional Interest)

Q20 Which of the three options proposed by the Joint Committee concerning the capital financing charge (notional interest) (ie option A, B or C at paragraph 8.28) do you most favour?

ACCA most favours option A. We do not accept the argument that private sector competitors, when setting prices, have to allow for interest costs on their borrowings and for a return on their capital employed. They may, in fact, choose to submit a bid which covers only their marginal costs, for example, if they are particularly keen to win a client or enter the market.

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