Archive for September, 2008
Oh sure, the sub-prime crisis and the federal bank bailout are all important, but let’s all keep our eyes on what is really, really important–the push to switch the U.S. from GAAP to IFRS.
I am somewhat frustrated that it is taking the SEC so long to get the proposed road map published. Despite labeling the coming publication as a proposal, everything said about it seems to scream out that a commitment to IFRS has been made. Do you recall the movie masterpiece Absolute Power? In one scene the Laura Linney character said to the Clint Eastwood character, “Father, what have you done now?!”
I keep reading and rereading the wording of the SEC August 27, 2008 press release, SEC Proposes Roadmap Toward Global Accounting Standards to Help Investors Compare Financial Information More Easily. FOR IMMEDIATE RELEASE 2008-184, trying to make sense of it all. “SEC, what have you done now?!”
WSJ reporters Kara Scannell and Joanna Slater have a take on 8/27, the “SEC Moves to Pull Plug On U.S. Accounting Standards“. Previously, the SEC announced its intention to pull the plug. What’s next? SEC finally pulls plug. Because the SEC is judge, jury and executioner on, we can conclude that GAAP is a dead man walking.
The move to IFRS in the United States is controversial. On one hand, business execs and large audit firms are having orgasmic fits of anticipation of windfall profits if the move to IFRS goes through. Investor groups, who will have to supply the windfall profits, are angry that the execs and the auditors have appropriated the investor pockets. Accountants, who care about getting things right, cringe at the thought of having to implement the loose standards of IFRS.
But it does not seem controversial from the perspective of the SEC. Why? SEC Chairman Cox, a bull politico, has been let loose in the financial system china house with predictable results. It is very unusual for an SEC chairman to have done such a poor job that a presidential candidate can score points by saying he should be fired.
Back to the proposal. Cox and SEC spokespersons attempt to deflect criticism by saying that this proposal does not commit the U.S. to IFRS. However, to the chagrin of investors and accountants this proposal does not decommit the U.S. from IFRS. An implicit assumption of eventual conversion to IFRS underpins the entirety of what the SEC is about.
The proposal is all about how to prepare for IFRS. Shall we prepare for IFRS this way, or that way?
I ask you. Does it not seem reasonable to conclude that if the proposal set before us is how to plan and get ready for IFRS, then the decision to adopt IFRS is either a difficult to change bedrock, or it is a very done-deal?
Commissioner Elisse B. Walters (possibly the commissioner least inclined to accept IFRS) describes one of the milestones, “Education and training are crucial in readying the United States for the transition of U.S. issuers from U.S. GAAP to IFRS reporting. Three years is not a very long time, and I believe that the Commission must do everything it can to educate investors and support the training of accountants, auditors, and others involved in preparing and using IFRS financial statements.” I think this shows, more clearly than anything else, that the move to IFRS is a done-deal. The process of educating (all) investors, (all) accountants, (all) auditors, (all) others, such as systems people is unnecessary and extremely wasteful unless IFRS is sure to be adopted. What will this one milestone cost? Undoubtedly a few hundred billion USD in opportunity cost! It could be more, depending on the assumputions used in your calculations. Does it make common sense that the SEC could call for the incurrence of a few hundred billion dollars while simultaneously saying the U.S. is not committed to IFRS? Give me a break.
Another of the desired milestones is for a test group of approximately 120 large companies to generate IFRS-based financial statements during the three year period 2009-2011. The CEO of British Petroleum announced that his company spent the equivalent of 100 million USD for the first year of IFRS reporting, with additional expense expected the second and third years. Extrapolating to the test group, the road map calls for certain U.S. corporations to spend approximately $20 billion USD in total to experimentally convert to IFRS. What would be the charge if all SEC reporting corporations were to convert to IFRS? Just shy of $1 trillion USD. Fortunately for my friends in the Big Four, almost all of this trillion goes into their pockets. What a windfall for them!. And, we haven’t even addressed the scientific fact that companies that report on IFRS instead of GAAP experience higher costs of capital and investors experience lower rates of return. My point is that requiring this $30 billion expenditure by some U.S. corporations seems to include an implicit promise that their sacrifice won’t be made in vain
My main point is there should be no need at all to plan as if we are going to convert to IFRS unless there also is a basic, unchangeable bedrock assumption that the switch to IFRS will be made, no matter what. Because the plan is being pitched so hard (and all commissioners are on public record as favoring going ahead with the plan), it seems obvious that even a blind man can see that an irreversible commitment to IFRS has been made.
How can SEC representatives stand before us with a straight face and say the U.S. is not committed to IFRS. It doesn’t ring true. As a good friend and trusted colleague would say, there’s something stinky to this story.
I would feel better if the proposal was about whether or not we should plan for the conversion to IFRS. I’d definitely feel much better if the proposal was about whether or not we should switch to IFRS at all. Unfortunately, the proposal certainly seems is about whether or not to adopt this one particular way to get ready for IFRS.
The logical order for the series of voiced questions is: (1) should we adopt IFRS, (2) if yes, is now the best time to start planning for it, (3) if yes, then is this the best plan to get ready for IFRS. However, the SEC has chosen to ask the questions in a different order: (1) is this the best plan to get ready for IFRS, (2) if yes or no, then no question, we’re going to start planning now, (3) if we have completed planning and preparation for the conversion, is the conversion something we really want to do after all?
Give me a break! Of course they have already decided to make the conversion. The IFRS decision is as irreversible as a 1913 decision to levy a federal income tax in the United States.
Every intelligent person I know tells me not to get worked up to fight the adoption of IFRS, because it simply will be a waste of time. They say, no use beating a dead horse, or no use beating your head against a brick wall, or no use beating your head against a dead horse. My reasoning brain agrees with them It will be a waste of time and utterly useless to attempt to fight the adoption of IFRS in the U.S. That fight took place a long time ago. It was very hush-hush. Then never told us about it when it happened. They won, we lost.
Never-the-less, I believe that there should be hope. Isn’t there always hope? No matter how dark the night, we can hope in a bright new dawn I refuse to give up hope that saner heads will arrive to intercede and justice will prevail.
Just because President Bush and the SEC are out to favor business executives and public auditing firms at the expense of investors and the general public, it does not mean that we have to accept it without a fight I hope that everyone reading this article will make a commitment to write in during the 60 day comment period with anti-IFRS sentiments. The exercise has only a snowball’s chance of survival in hell, but I feel life is most worth living when the fight is for good to triumph over bad.
Over and out – – David Albrecht
I got off the phone with Kevin Callahan of the SEC press office at 6 p.m. ET on Friday. He seems very sincere. After communicating a couple of times via e-mail, I have no doubt about his belief in the things he said.
He said that there is no science as to how long it takes from a Commission vote of approval to when it is ready for publication in the Federal Register. He said that it might take just a bit more than a week, or it could take a couple of months. It all depends on the complexity of the issue and the number of SEC departments that are involved.
Although he did not have a copy of a draft of the proposal in front of him, he kept directing me to the first paragraph of the August 27 press release that announces the proposal: SEC Proposes Roadmap Toward Global Accounting Standards to Help Investors Compare Financial Information More Easily. FOR IMMEDIATE RELEASE 2008-184
Washington, D.C., Aug. 27, 2008 – The Securities and Exchange Commission today voted to publish for public comment a proposed Roadmap that could lead to the use of International Financial Reporting Standards (IFRS) by U.S. issuers beginning in 2014. Currently, U.S. issuers use U.S. Generally Accepted Accounting Principles (U.S. GAAP). The Commission would make a decision in 2011 on whether adoption of IFRS is in the public interest and would benefit investors. The proposed multi-year plan sets out several milestones that, if achieved, could lead to the use of IFRS by U.S. issuers in their filings with the Commission.
So, there are two things to keep separate. There is a proposed developmental journey (what the SEC terms the road map) to take place 2008-2011, and an eventual final decision to be made in 2011.
He said that all the Commission has approved at this point is putting the proposed road map up for public comment. They have not approved the events of the next three years, but proposed milestones for between now and 2011 to prepare for Commission’s ultimate decision on IFRS. He said that the specific issues for which public comment is being elicited, as well as to the uses of these comments, would be detailed in the published proposal. He said in general that public input is being elicited on the road map and on the decision in the long run (2011).
Since I’m a professor reputedly good at explaining things, this is how I understand his comments. I think he means that what the Commission has approved at this point is pretty limited. They have not approved setting in motion any processes that could lead to realizing milestones. But they have approved the set of milestones (or important developments) they want or prefer to see in the future, upon which they believe future decisions will hinge. I think he implied that there definitely is to be a road map, but the particulars could depend on the public comments, but perhaps I’m wrong on this. I’m sure it will all be made cleaer in the published proposal.
He was quite clear that neither contemporary events nor political issues speculated upon in recent on-line articles (CFO, ConcurringOpinions, The Summa, etc.) are having any influence on what I called the “apparent delay.” He emphasized that there is no delay, it is simply a matter of getting the report ready for publication.
He concluded by saying that its publication could be expected within three weeks.
I think this trumps my earlier journey into fantasy land– “Cold Feet, Mr. Cox?”
Over and out – – David Albrecht
I just talked with Liza McAndrew Moberg, Professional Accounting Fellow, Office of Chief Accountant , Securities and Exchange Commission, Washington, D.C., the person apparently designated to respond to my inquiry for more information.
She said that she had no knowledge when the details (about the SEC road map to IFRS) would be released. She also said that she had no knowledge about reasons as to why the details have not been published by now. She would not comment on public conjecture about a possible delay.
She said that information and a statement about this issue could be obtained only from the SEC press office. At this time, I’m awaiting a return call from Kevin Callahan.
Over and out – – David Albrecht
Posted in Accounting, IFRS, Regulation, tagged Accounting, Accounting regulation, Financial system infrastructure, GAAP, IFRS, Regulation, Road map to IFRS, Securities markets on September 26, 2008 | Leave a Comment »
The subject of today’s essay is to debate the notion that the time is right to kill off United States Generally Accepted Accounting Principles (GAAP). As we all are aware now, the Securities and Exchange Commission (SEC) announced on August 27, 2008, a road map for the transition from GAAP to International Financial Reporting Standards (IFRS).
In this article I argue that the U.S. moving to IFRS cannot be successful because there is no infrastructure for an integrated international financial system. Such an infrastructure is necessary for the potential of IFRS to be realized. If the potential of IFRS cannot be realized, then there is no reason for the U.S. to adopt IFRS. (more…)
Another long week. These images are for those needing a smile. I’m using royalty free images from Broderbund and my own warped sense of humor. My renditions are not in the public domain.
Over and out – – David Albrecht
Professor Lawrence A. Cunningham, of George Washiington University Law School, last night suggested in “Where’s the SEC?” that there is something substantial to be read into the SEC failing to open up the 60 day comment period on its proposed road map to IFRS. Mr. Cunningham suggests that SEC chairman Christopher Cox has cold feet!
The SEC formally announced its road map to IFRS on August 27, 2008. 29 days later, we are still waiting for it.
If Cunningham is correct, this is exceedingly good news for American investors. I am saying now in print for the first time that American investors stand to lose trillions if the U.S. switches corporate financial reporting from following U.S. GAAP to instead following IFRS. Large CPA firms will take a huge chunk of this vast sum (Jensen), but the major part of it goes to Europe in a massive wealth transfer.
Getting back to Cunnigham, how could the Cox delay be? Cunningham says:
First, Mr. Cox may have decided now is not the best time for the SEC to issue a Release that would be largely deregulatory and elevate managerial and auditor interests over those of investors and other users of financial reports. Second, Mr. Cox may believe that he should have unanimous Commission support for such a controversial Release. This may be more difficult now that he must work with a full slate of Commissioners, compared to earlier this year when vacancies existed. Some current Commissioners may side with investors and oppose the Release.
More important is Cunningham’s closing paragraph, in which he essentially says that the emperor has no clothes. His words are (emphasis mine):
Despite the SEC’s earlier exuberance, there no longer appear to be reasons for Mr. Cox to continue a quixotic campaign to move the US from its own to international accounting standards. For Mr. Cox, the consequence is being deprived of a legacy he sought. For investors, that would be a good thing too.
Well said. Very well said. There ought to be an award for such well-said remarks.
Of course, all of this is pure speculation. I wrote earlier that Mr. Cox has all the power here. Never-the-less, Republican presidential candidate John McCain’s threat to can his rear end may have taken some of his power away. Good for us.
Over and out – – David Albrecht
1 p.m. reality check. A friend just e-mailed to remind, “Resistance if futile!” He is correct, of course. The delay is undoubtedly meaningless.
Another friend, extremely well-connected, just e-mailed to say, “I understand that it’s likely the SEC proposal on IFRS will be released sometime next week. Of course, I heard that same thing about three weeks ago.”
5 p.m. CFO reporter Alix Stuart just got an article up, “IFRS Timetable Not on Time.” He has been in further communication with Cunningham. After reviewing comments of a few critics (including Niemeier), Stuart says:
Regardless of what has created the delay in publishing the timetable proposal, consensus is building that it may come too late for the timetable to unfold in its current form. “Even those who say a release is likely appreciate that there’d be a 60-day comment period, so it’s unlikely the SEC could turn around and do much,” no matter whether Cox finishes his term or resigns early, Cunningham said in an e-mail to CFO.com.
The coming turnover in the White House is likely to push out IFRS implementation far beyond the “date certain” that seemed so close in August. The next SEC chair will likely revise the proposal and call for “more detail, study and evaluation, which will take much more time,” says Cunningham.
So there you have it. It seems possible, but not conclusively so, to conclude that the transition to GAAP has been delayed a bit. However, I’ve promised to remind myself 1,000 times over, “Resistance is futile” before I get too enthused again.
Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile. Resistance is futile …
Over and out – – David Albrecht