For those who couldn’t find the proposed roadmap released by the SEC when they went to the Commission’s site last week, don’t blame yourself. You need an actual roadmap to find it.

The proposed roadmap, all 165 pages of it, may be found at www.sec.gov/rules/proposed/2008/33-8982.pdf in the SEC proposed rules section. There was no mention on the SEC home page. And If you went to the SEC special global accounting standards section via the hyperlink on the SEC home page, you would have found an outdated page last referring to August 8th roundtable on IFRS.

There are many interesting aspects of the proposed roadmap that should be closely perused and hopefully commented on, but one particular sentence, which refers to the estimated 110 issuers who are expected to volunteer to convert to IFRS in 2010 for their financial statements beginning after Dec. 15, 2009, sticks with me: “Total estimated costs for the approximate minimum of 110 issuers estimated to be eligible would therefore be approximately $3.5 billion.” That’s just under $32 million per issuer. And my guess is, that amount is an underestimation.

I also believe there is an underestimation of how difficult a conversion to IFRS will be for public companies, or the significance for, and impact on, private companies and not-for-profits. But that doesn’t seem to worry some, as they seem to believe that moving from GAAP to IFRS is inevitable, with the only question being the timing. Yes, there are prescribed milestones, but they would only seem to possibly slow the conversion in those experts’ eyes.
 
Personally, I would be more comfortable with a more advanced system to getting   companies to IFRS reporting, and hopefully that will develop as we go down the road. But if the presentation of the proposed roadmap by the SEC is any indication, a rocky and expensive trip can be expected. SEC: Where is GPS when you need it?    
- ---------------------Comment on earlier column--------------------
The text that follows is from two e-mails that I received commenting on my column from last week entitled "Growing Concern with Going Concern." While I share your opinion that more accountants will be named in situations where their clients go down in a blaze of glory, your concern appears to me to be a bit overstated.  My reading of our reference materials (Thomson/PPC) indicate that "going concern" paragraphs should not be used unless the client's statements do not contain adequate disclosures.  They also suggest that additional paragraphs generally not be added to our non-audit reports.  In some 35 years in this business, I don't recall ever using a going concern "qualification" in a non-audit situation (but my memory isn't perfect).  I'm certain I have not used one in a compilation engagement.   I would also add that there is virtually no logic to any sort of qualification in a compilation report since it says we did nothing but put some information given to us into the form of a financial statement.  Of course, those learned members of our profession that get up on the witness stand and state that the defendant accountant should have found the mistake in the financial statement sort of make the compilation letter totally meaningless and most compilation engagements a farse unless you like to roll the dice with potential litigation.  But that's another story for another day.   Tom Tone Tone, Walling & Kissinger  Westlake Village,  Calif.

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