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Comment Letters on SEC Proposed Rules

Comment Letters on SRO Proposed Rules

Legislative Update

S7-4-00
Proposal: Rel. #: File #: Comments Due: # Letters to Date:
Concept release on international accounting standards. 33-7801; 34-42430 S7-4-00 5/23/00 84

Letters Released June 12-23: Date: Position:
Societe Generale de Beligique 6/20/00 This group supports the use of IAS. It believes that the reconciliations suggested for financial statements made under IAS only result in extra work without significant benefits.
Int'l. Councils of Securities Ass'ns. 6/19/00 ICSA supports this measure, but believes that applying every aspect of U.S. GAAP could be interpreted as hostility by the SEC towards international accounting.
Swisscom 6/19/00 Swisscom supports the use of IAS as a basis for financial statements. The use of U.S. GAAP for specific issues would only reduce consistency, in Swisscom's view. Swisscom is also against the modification of IAS to match U.S. GAAP due to the increase in workload.
Financial Executives Institute 6/16/00 This institute believes that the acceptance of IAS as the only permissible alternative to U.S. GAAP would likely improve the present state of affairs.
Federation Bancaire de l'Union Europeenne 6/14/00 EBF's experience with national standards leads it to believe that efforts by preparers and auditors, together with the influence of users of financial statements, are key factors in promoting consistent interpretation of standards. The federation believes that once IAS gains widespread acceptance, the growing interest and expertise in their application will accelerate the elimination of any existing inconsistencies of application.
London School of Economics 6/13/00 A professor of accounting at the London School of Economics encourages the SEC to support the potential use of IASC standards for all cross-border listings and to look to FASB to bring its own standards into line with the best standards available internationally.
Ascom Management Ltd. 6/9/00 This company, as part of the Federation of Swiss Industrial Holding Cos., supports adoption of the Int'l. Accounting Standards.
Von Roll Management Ltd. 6/8/00 This company, as a member of the Federation of Swiss Holding Cos., supports the adoption of IAS and refers the SEC to comments in the Federation's letter.
Zeff, Stephen 6/6/00 An expert on financial reporting regulation analyzes the SEC concept release and suggests that perhaps the SEC will only abide the IASC standards for foreign registrants if they are so much like U.S. GAAP as to be virtually U.S. GAAP. He also points out that the IASC board's interest in securing the SEC's endorsement means that the SEC will be more involved in the setting of international accounting standards than it has ever been in setting U.S. accounting standards.
Financial Accounting Standards Board 6/5/00 FASB advocates the adoption of the IASC standards, but only if a reconciliation of IASC-based financial statements to U.S. GAAP is required. The board believes that the IASC standards are only one element of a global financial reporting infrastructure and that the other elements are not yet sufficiently developed to ensure the rigorous interpretation and application of the IASC's core standards.
Global Financial Reporting Advocacy Committee of AIMR 6/5/00 The majority of this committee believes that IAS is of sufficient quality to be accepted by the SEC for use by foreign registrants without reconciliation provided that the other elements of the financial reporting and disclosure system are comparable to those in the current system for domestic registrants. The committee anticipates that acceptance of the core standards will encourage more companies to adopt IAS, foster further improvement of the standards and test the market implications of using IAS.
Cairns, David 6/3/00 This former IASC secretary-general favors the use of IAS, believing that it provides a sufficiently comprehensive accounting framework that should result in the same level of transparency and comparability as U.S. GAAP. He believes that the SEC should accept IAS financial statements from foreign issuers without reconciliation or modification to U.S. GAAP.
Ravlic, Tom 5/25/00 This freelance journalist feels that, although it deals with a broad range of issues, the IASC accounting framework leaves some gaps in guidance that should be filled by domestic GAAP until such time as the IASC can provide "fresh product." He also warns that failing to enforce the standards uniformly would defeat the purpose of having a single language.
Chazen, Jerome A. 5/23/00 This Columbia Business School professor is in favor of the adoption of IAS. He believes that IAS is of sufficient quality to provide appropriate measurements and is likely to lead to more meaningful comparisons than the current system. He states that he is aware of no evidence that the adoption of IAS will in fact lead to lower quality information.
Chisnall, Paul 5/23/00 This U.K. director fully supports the global harmonization of accounting standards and believes that the SEC's existing enforcement powers allow for the immediate acceptance of statements prepared according with IAS without reconciliation to U.S. GAAP.
Institute of Chartered Accountants in Australia 5/22/00 The institute supports the SEC's adoption of IAS in place of the current requirement that U.S.-based investors comply with or provide a reconciliation to U.S. GAAP. The institute reports that it has supported the Australian Accounting Standards harmonization with the IASC and has found the IASC to be of sufficiently high quality to enable investors to make economic rational decisions.
Haluza-DeLay, Randy 5/15/00 This American, who is currently residing in Canada as an affiliate of the School of Outdoor Recreation, Parks and Tourism at Lakehead University, is against the adoption of IAS as he feels it will weaken the current rules. He feels that relaxing U.S. rules to reach a common denominator would not advance agreements on environmental accountability but would erode shareholder needs.
Int'l. Federation of Accountants Secretariat 5/10/00 The technical director of the Int'l. Federation of Accountants (IFAC) Secretariat, sister organization to the IASC, informs the SEC that IFAC is working to strengthen its monitoring abilities. It is considering a "forum of firms" that will restrict membership to those firms with an independent, firm-wide, quality review program, and is considering an accreditation program in international accounting and auditing standards for individual accountants.

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