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IFRS Comment Period To End on April 20

April 19, 2009

Monday is the deadline for commenting on the SEC’s proposed Roadmap to the adoption of IFRS. The SEC has received about 130 comment letters to date. In their rule release, the SEC is requesting comments on over 70 questions. Following is a sample of some of the questions asked by the SEC:

  • Do commenters agree that U.S. investors, U.S. issuers and U.S. markets would benefit from the development and use of a single set of globally accepted accounting standards?
  • Do commenters agree with the timing presented by the milestones? Why or why not?
  • What are commenters’ views on the mandated use of IFRS by U.S. issuers beginning in 2014, on an either staged-transition or non-staged transition basis?
  • What do commenters believe would be the effect on convergence if the Commission were to follow the proposed Roadmap or allow certain U.S. issuers to use IFRS as proposed?
  • What steps should the Commission and others take in order to determine whether U.S. investors, U.S. issuers, and other market participants are ready to transition to IFRS?
  • Do commenters agree that certain U.S. issuers should have the alternative to report using IFRS prior to 2011?
  • Is limiting the proposal to the largest 20 competitors by market capitalization an appropriate criterion?
  • Are there any considerations that may make it difficult for an eligible U.S. issuer to file IFRS financial statements?
  • What would affect a company’s willingness to use IFRS if it were eligible to do so?
  • Is there any reason why an issuer would be unable to assert compliance with IFRS as issued by the IASB and obtain the necessary opinion from its independent auditor?

Comments may be submitted electronically using the SEC’s comment form or by sending an e-mail to Include File Number S7-­27-08 in the subject line; or through the federal rulemaking portal. Paper comments should be submitted in triplicate referencing File Number S7-27-08 to Elizabeth M. Murphy, Secretary, Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549-1090.

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