At the time of the data collection, a total of 3064 comment letters had been generated
in response to the 24 documents. Out of those, 1815 related to projects which are
considered to have been completed. Table 4.1 outlines the 24 documents and the
number of corresponding comment letters, as well as the completion status of the
project to which they relate. The greatest volume of comment letters was received for
the exposure draft Hedge Accounting in 2010. This is an issue which had been
controversial since the inception of the IASB. However, the high volume of comment
letters may be due to a combination of the salience of the issue and the overall
increased levels of participation in the lobbying process as more countries came to
adopt IFRS. The period prior to European and Australian adoption in 2005 generated
an average of 102 comment letters per issued document, whereas the period after 2005
generated an average of 138 comment letters and since 2009, an average of 166. This
is further illustrated in Figure 4.1 which presents the number of comment letter
responses to each letter and a three-document average trend line