Interestingly, the SEC has already posted one lengthy comment. In a letter dated August 10, 2007, Professor Lawrence Cunningham (George Washington University Law School) responds to Concept Release No. 33-8831 in his three capacities: “as a private investor with a sizeable portfolio and skepticism about efficient market theory…; an active scholar interested in the role of accounting information in capital markets…; and as a university professor who has taught accounting to law students for 15 years and written two books on accounting for law school instruction…”  (He’s also authored How to Think like Benjamin Graham and Invest like Warren Buffett (McGraw-Hill, 2002)).

In answer to whether the SEC should permit U.S. issuers to prepare financial statements in accordance with IFRS (and the underlying presumption of comparability between U.S. enterprises and foreign competitors): “It would amount to a leap of faith,” Cunningham says.

The unstated but possibly serious price would be a false sense of global comparability from a veneer of nominal uniformity—uniformity in written standards could disguise considerable diversity in actual practice.

For more of Professor Cunningham’s comments, including the potential conflict between IASB and FASB “standard-setting powers,” click here.