As businesses continue to expand their international footprint, it is increasingly sub-optimal to be using different reporting standards, which sometimes increase costs while decreasing comparability. Just as international business has benefited over the last 30-odd years from the increased shared use of English, so too will global companies reap the benefits of one financial reporting language.

Based on recent trends, that language is most likely to be International Financial Reporting Standards (IFRS). Currently, more than 100 countries either permit or require IFRS for financial reporting. The European Union adopted IFRS for its listed companies in 2005, replacing more than 20 different accounting languages with IFRS virtually overnight. The United States, the world’s largest economy, however, remains notably absent from the IFRS party.

Like many in this country and elsewhere, we were hoping that the U.S. Securities and Exchange Commission (SEC) would announce a mandatory date for switching to IFRS by U.S. public companies. Instead, the Commission reaffirmed that it expected to decide in 2011, provided resolution of certain issues. The current FASB/IASB convergence projects underway must be completed, and six provisions of a staff work plan must be addressed. Although some of these areas carry over from the November 2008 “Roadmap” release, new areas of focus have been added, including an examination of the U.S. regulatory environment, and an analysis of the scope and timing impact on issuers in the context of compliance with corporate governance provisions. In our view, however, reaffirming that you will decide is not the same as deciding.

There is no question that the decision to mandate IFRS is a critical one – one not to be taken lightly. To inform that decision, the steps announced today would be helpful, but are they truly necessary? Until there is a decision, until people have at least a tentative date, there will be almost no movement toward adoption.

Preparers, analysts, educators, auditors, and other participants will adopt a “wait and see” attitude. Who could blame them? Why risk scarce resources on something that may or may not happen sometime after a “who knows when” future decision? Some would argue that such an important decision, once made, is not easily reversed. We say, make a decision, set a date. There is nothing preventing the SEC from deciding later to move that line in the sand. Maybe the convergence projects were not complete, or the work plan revealed some unexpected concerns. Nothing of this magnitude comes ashore on a wave fully formed. It’s not as if we lack precedent for delaying rules in response to unanticipated implementation difficulties.

The stakes are high. Whether the U.S. races or crawls toward IFRS could mean the difference between staying in front or falling behind. The rest of the world is moving forward, boldly. Major economies like Japan, China, and India already have chosen IFRS. It is unrealistic — and risky — to think that we can stand outside looking in forever. If we don’t want our influence and opportunities stripped away, we must make sure that we keep a seat at the table.

Taking the longer view, with establishing one financial reporting language as the goal, we view the SEC announcement as a step forward. The announcement is on course with the “Roadmap” that was issued in November 2008. We applaud Chairman Mary Shapiro, Chief Accountant Jim Kroeker, and others at the SEC for their time and effort spent poring over the 200-plus comment letters, considering the multitude of issues, and debating a final decision to switch accounting standards in the U.S.

 

Neither the benefits nor the costs of a switch to IFRS for U.S. companies and markets are immediately apparent or easy to quantify. In the face of this level of uncertainty and this level of change, we accept the need for thoughtful deliberation. However, bold, decisive action is what America is about. We must get back in the race – soon – or risk falling behind the rest of the world.

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