27 September 2007 — Consultation Response
FEE has submitted its comments to the SEC both on the Proposed Rule Acceptance from Private Issuers of Financial Statements Prepared in Accordance with IFRS without Reconciliation to US GAAP and Concept Release on Allowing US Issuers to Prepare Financial Statements in Accordance with IFRS. FEE supports the European Commission’s request for recognition of ‘IFRS as adopted by the EU’ as being equivalent to US GAAP given the relatively small differences, if at all that exist with ‘full IFRS’. If an equivalence decision would not be possible to achieve FEE suggests as a compromise that the SEC would allow for those foreign private issuers only a reconciliation from “IFRS as adopted by the EU” to “full IFRS” where both are not identical. Foreign private issuers in this case could be left the choice to reconcile to “full IFRS” or to US GAAP, whichever is the least cumbersome for those entities. FEE in addition strongly supports the intention to allow US issuers to prepare financial statements in accordance with IFRS.