Accounting and Regulation: SEC Staff Pours Cold Water on Convergence

July 17, 2012

SEC Staff report highlights differences in accounting approaches; gives no implementation date.

Fri Reg and Accting - Ledger smallThe Securities and Exchange Commission’s Staff report on a work plan to implement international accounting standards released July 13 is really a long way of saying, “Thanks, but we’re not ready yet and may never be ready.” This was a bit of a disappointment to some of the accounting standard standard bearers.

The report, officially the “Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers,” also made much of the fact that it was strictly a “Staff report” and did not reflect the views of the Commission or any Commissioner. It mentions this several times before it gets to the executive summary, after which it informs that it was not meant as an answer, that a decision has yet to me made, and further examination is needed.

“The Work Plan did not set out to answer the fundamental question of whether transitioning to IFRS is in the best interests of the U.S. securities markets generally and U.S. investors specifically. Additional analysis and consideration of this threshold policy question is necessary before any decision by the Commission concerning the incorporation of IFRS into the financial reporting system for U.S. issuers can occur.”

The report details where Financial Accounting Standards Board (FASB) and International Accounting Standards Board (IASB) accounting standards dovetail (Earnings Per Share, Share-Based Compensation, Debt, Business Combinations and others) and also concentrated on some of the meatier parts of where they diverge (Impairment, Income Taxes, Inventory, . It also made the point that it is not supported by the vast majority of commenters. “[E]arly in the Staff’s research, it became apparent to the Staff that pursuing the designation of the standards of the IASB as authoritative was, among other things, not supported by the vast majority of participants in the U.S. capital markets and did not appear to be consistent with the methods of incorporation employed by the other major capital markets around the world.”

With that in mind, the Staff “focused on other methods of potential incorporation,” such as its condorsement idea of 2010. This the Staff report suggests is actually consistent with other jurisdictions that have mechanism to incorporate IFRS. It was also one of the factors the Staff considered in its research, along with the cost impact to converting to IFRS (“Burden of Conversion”) as well as the simple fact that GAAP, or Generally Accepted Accounting Principles, is now embedded in countless contracts, making it nearly impossible to ever reconcile (“Reference to US GAAP”).

Where’s the action plan?
Overall the report was a disappointment of sorts to the FASB as well as its counterpart, the IASB. Also unhappy was the UK Financial Reporting Council. While they welcomed the report, all were disappointed that no date for implementation was given. The SEC has been working on its Work Plan for almost two years and had said that it would make a decision on IFRS incorporation in 2011 but still hasn’t.

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