Chairman Mary Schapiro
100 F Street NE
Washington DC 20549
Dear Chairman Mary Schapiro,
With this letter I indicate my support for Charles Niemeier for Chief Accountant of the Securities and Exchange Commission.
I am accounting professor and a self-described accounting theorist. I have closely followed the Securities and Exchange Commission, the Financial Accounting Standards Board, the Public Companies Accounting Oversight Board and the International Accounting Standards Board for some time. As a result, I became aware of the extraordinary qualifications of Mr. Niemeier.
The Chief Accountant, America’s First Accountant, establishes and maintains U.S. government policy with respect to the FASB, PCAOB and IASB. Charles Niemeier is uniquely positioned as having prior experience with the SEC and PCAOB, and having worked with the FASB and IASB. An appointment as Chief Accountant will serve to help him leverage all aspects of his past to move the U.S. forward in very difficult and perilous times. There is no person today in government accounting regulation/standard setting in whom I have as much trust and respect as Charles Niemeier. He is the person best qualified to move the U.S. forward with respect to accounting.
I believe that his primary qualification is his great mind that enables him to think in terms of a very broad world view. His ability to discern trends and understand difficult issues, integrate them, and then correctly reason through to necessary remedies and actions is very special indeed. In the past 15-20 years, the only other great accounting mind (outside of academia) that comes to mind is Dennis Beresford, former chair of the FASB and now accounting professor at the University of Georgia. Niemeier’s speeches are well-researched and very insightful. Some are required reading for my accounting majors.
Not to be overlooked is his dedication to the American investor. There is not even the hint of a suggestion that he has ever acted to advantage corporate interests over those of investors. Moreover, he is as pro-regulation as anyone I’ve ever come across. His September 18, 2007 speech to a NYSSCPA conference is the best defense I’ve seen about how strong regulation enhances the U.S. cost of capital advantage in world corporate markets (http://www.pcaobus.org/News_and_Events/Events/2007/Speech/09-18_Niemeier.aspx).
Another qualification he possesses is the respect and admiration of the U.S. world of accountants. His September 10, 2008 speech to NYSSCPA (http://www.pcaobus.org/News_and_Events/Events/2008/Speech/09-10_Niemeier.aspx) generated headlines around the world, literally. It generated dozens of comments by conference attendees as the best defense of U.S. GAAP ever heard. Quite honestly, it is this national respect that makes him such a serious candidate for Chief Accountant.
He has the respect and love of his staff.
It has been mentioned in the press that he is the anti-IFRS candidate for Chief Accountant. Given his background, I think it better to say that he would work toward accounting convergence as long as the convergence did not disadvantage American investors in any way. Some have suggested that your predecessor along with the FASB chair sold out U.S. accounting far too cheaply. This will never happen under Charles Niemeier. An additional factor is that many of his views are similar to yours. For example, he favors U.S. inspection of foreign auditors that serve U.S. companies, just as you do. I’m sure that the two of you will form a great, great team.
I’ve read every word you’ve spoken and written during the confirmation process and after. I am becoming convinced that you will be an outstanding Chairman of the SEC. If you are serious about making accounting the best it can possibly be in the U.S., then I’m sure you should appoint Charles Niemeier as Chief Accountant.
David Albrecht, Ph.D., CPA
Associate Professor of Accounting
Bowling Green State University