Financial Accounting and Reporting Section of the American Accounting Association Financial Reporting Policy Committee File No. S7-13-07 Response to the SEC Release: ACCEPTANCE FROM FOREIGN PRIVATE ISSUERS OF FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH INTERNATIONAL FINANCIAL REPORTING STANDARDS WITHOUT RECONCILIATION TO U.S. GAAP

The Financial Reporting Policy Committee of the Financial Accounting and Reporting Section of the American Accounting Association responded to the SEC's July 13, 2007 proposal to accept financial statements prepared in accordance with International Financial Reporting Standards (IFRS) from foreign-private issuers without reconciliation to U.S. GAAP (the SEC subsequently voted in favor of the proposal on November 15, 2007). Our commentary summarizes and interprets relevant academic research. Our main findings are that material reconciling items exist that are relevant to U.S. investors, there are differences in the implementation of uniform standards and that compliance to IFRS or U.S. GAAP by foreign firms is a concern, foreign firms benefit from greater access to capital by listing in the U.S. and the U.S. requirements do not make the U.S. market less attractive to foreign firms, U.S. investors tend to prefer U.S. GAAP suggesting that elimination of the reconciliation may discourage U.S. investment in foreign firms, and that U.S. GAAP - IFRS harmonization might improve the functioning of the U.S. capital markets. We conclude that eliminating the reconciliation requirement was premature.