We support SEC's proposal to eliminate the reconciliation

  • Deloitte Comment Letter Image

25 Sep 2007

Deloitte has submitted a letter supporting the SEC's Proposed Rule, Acceptance from Foreign Private Issuers of Financial Statements Prepared in Accordance With IFRSs Without Reconciliation to US GAAP. We do suggest, however, that when a non-US registrant uses local GAAP or a 'jurisdictional version' of IFRSs, it should be permitted to reconcile to IFRSs as an alternative to reconciling to US GAAP.

Here is our overall view:

We agree with the Commission's proposal to eliminate the US GAAP reconciliation for foreign private issuers that use IFRSs and believe that it is an important step toward developing a single set of globally accepted accounting standards. We note, however, that there may be issues in certain jurisdictions with the proposal that use of IFRSs is required if a company wishes not to reconcile to US GAAP. In European countries, for example, endorsement or approval of IFRSs by local authorities is required before such standards can be applied. Consequently, when a foreign private issuer is required to follow the 'jurisdictional version' of IFRSs in describing how it has prepared its financial statements, it may not be able to make an explicit and unreserved statement of compliance with IFRSs because certain standards have not yet been endorsed or approved by the local authority.

Given these constraints, we believe that the Commission should consider allowing foreign private issuers that use local GAAP (including jurisdictional IFRSs) to reconcile to IFRSs instead of US GAAP, which would give them a choice of one of the following:

  • IFRSs
  • Local GAAP (including jurisdictional IFRSs) reconciled to either US GAAP or IFRSs
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