Reconciliation. "Strong arguments can be made for the rapid elimination of the reconciliation requirement. Reconciliation is an additional cost for foreign private issuers registered in the United States. That cost is hard to justify. In the discussions at the SEC's IFRS roundtable earlier this year, we learned that the reconciliations are of limited use to those who look at financial statements."

Consistent application. "The SEC is working with our fellow international securities regulators and accounting standard setting bodies to achieve the consistent application and interpretation of IFRS. The SEC staff, which receives IFRS filings from all over the world, is in an excellent position to spot potential issues, but it does not intend to become the arbiter of IFRS. I hope that if the rule is adopted and properly implemented, investors will benefit from the elimination of the costly reconciliation requirement, and businesses will be able to refocus their resources on more productive measures."

Possible use of IFRSs by US companies. "As further evidence of the global nature of the capital markets, the SEC likely will consider whether to take the additional step of permitting U.S. companies to select between using U.S. GAAP and IFRS. You can easily see the utility of IFRS for multi-national American companies that access international capital markets and have foreign-based competitors. Last month, the SEC voted to issue a concept release on permitting U.S. issuers to file their financial statements using IFRS rather than U.S. GAAP. That would leave the choice between U.S. GAAP and IFRS to the markets. If investors prefer one set of accounting standards over another, they may well reward with premium pricing those issuers who use the preferred set."