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AP3s svar till ISABs remiss om kostnadsföring av optionsprogram

Internationella redovisningsrådet presenterade i december 2002 ett förslag till ny redovisningspraxis som innebär att optionsprogram tas upp som en kostnad i resultaträkningen. Alla intressenter inbjöds att kommentera förslaget.

Eftersom detta är en viktig fråga ur ett ägarperspektiv har AP3 valt att skicka in ett remisssvar. Nedan kan du läsa Tomas Nicolins följebrev till remisssvaret. Remisssvaret i sin helhet finns bifogat nedan i pdf-format.

Exposure draft of share-based payment

Dear Sir David,

We appreciate the opportunity to respond to the International Accounting Standards Board´s exposure draft of its proposed IFRS Share-based Payment.
This letter represents the views of the Third Swedish National Pension Fund (AP3), one of four buffer funds in the public Swedish pension system. The Riksdag (Swedish Parliament) has given each of the four funds a mandate to generate the best possible long-term return on capital, in relation to the funds’ liabilities in the pension system. The market value of fund assets as of 31 December 2003 was SEK 120.2 bn (EUR 13.1 bn), of which 55 percent was invested in a global equities portfolio. The overall return target, mentioned above, constitutes the basis of the Fund’s activities in the Corporate Governance arena.

Summary of views

Our response should be seen as an owner’s point of view and therefore we do not cover all technical aspects of the proposal. Our comments also focus on the situations where share-based payments are used in exchange for employee services.

In general we agree strongly with the IASB´s requirement that share-based payments, granted at less than fair value, must be recorded as an expense in the financial statements. We also strongly agree with the requirement to measure the transactions at fair value and to use grant date measurement. However, we believe that the standard is in some respects too complex, particularly the calculations in paragraph 15 and Appendix B. We also find the disclosure requirements too extensive.

The subject of management remuneration is highly sensitive in the public opinion. Therefore, in order to improve transparency and credibility, it is of vital importance to avoid overly complex accounting practices in this area. There is no reason why the calculation of the cost for equity-settled share-based transactions should be any more complex or handled in any greater detail as, for example, depreciation of fixed assets. We are also concerned that too much complexity will lead to poor applications.

In our opinion, the calculations in paragraph 15 are overly detailed. Our preference for principles that are easy to use and understand also leads us to prefer straight-line depreciation of fixed assets. Not because it is a superior method, but simply because the method is easier to use than other, more accurate, methods.

We also suggest that the IASB recommend one of the option pricing models and to require the companies to comply with that model or else explain why they use a different one. Neither do we believe that it is necessary in general to require unlisted companies to use the standard.
The Fund’s detailed comments on the exposure draft have been prepared in collaboration with the consultant Peter Malmqvist. If you wish to discuss more issues raised in our commentary, please contact Mr. Malmqvist. See contact details below.

Yours sincerely,

Tomas Nicolin

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