At the US Chamber of Commerce conference last week, Mr Schnurr outlined three previous alternatives regarding the use of IFRS in the United States, including: (1) the outright adoption of IFRSs, (2) providing US registrants with the option to file IFRS financial statements, and (3) the so-called "condorsement" approach". During today's speech, Mr Schnurr provided an example of how IFRS could be incorporated in the US reporting system:

[W]e understand that some domestic issuers may, now or in the near future, prepare IFRS-based financial information in addition to the U.S. GAAP based information that they use for purposes of SEC filings. However, regulatory constraints may dissuade some issuers from providing this information, as current SEC rules would consider IFRS-based information to be a “non-GAAP” financial measure for a domestic issuer. Should IFRS-based information continue to be considered “non-GAAP” financial measures subject to the requirements for such measures, or should it be thought of differently? Under this line of thinking, issuers that do not believe IFRS-based information would be beneficial to investors would not be forced to undertake what we understand to be, in some cases, significant implementation costs. 

In her speech, Ms Erhardt examined IFRS-readiness of investors, issuers, and securities regulators today compared to 10 years ago, when the SEC staff began to look at whether accepting IFRS financial statements from foreign private issuers without a reconciliation to US GAAP should be recommended to the Commission. She concluded that members of these three groups are ready for the most part; they have sophisticated knowledge and experience with IFRSs though some groups (particularly retail investors) may not be "as comfortable" with IFRS as US GAAP. Ms Ernhardt discussed the SEC staff and its acceptance of IFRS financial statements from foreign private issuers without reconciliation to US GAAP:

I believe . . . that foreign private issuers may be subject to different disclosure requirements from those of U.S. issuers because effectively in exchange for this differential disclosure U.S. investors are able to achieve international diversity in their investment portfolios by buying and selling securities of foreign companies within the protections of the U.S. capital markets system.  As a point of fact I do not think this differential disclosure line of thinking would apply in considering whether to provide an IFRS reporting option to U.S. issuers, although of course other lines of thinking would come into play in considering this. 

Both speakers echoed that the IFRS dialog should continue in the United States. Mr Schnurr stated that he hoped to be ready in the "next few months" to discuss with the SEC Chair and Commissioners all of the alternatives and the related problems and concerns to reach a final recommendation. He stated:

Chair White and I both recognize that any continued uncertainty around IFRS results in uneasiness for investors across the globe. Therefore, it is a priority of mine to bring a recommendation to the Commission in the near future with the hope of resolving, or at least lessening, this uncertainty.

Both speeches are available on the SEC's website:

• Jim Schnurr's speech, including remarks on other issues including revenue recognition
• Julie Erhardt's speech