July 20, 2008
There appears to be a VERY DANGEROUS assumption that is being made by those who are in favor of replacing US GAAP with IFRS. That assumption is that Corporate America's business community including its accountants and lawyers are capable of sound judgment and reasonable decision making with respect to the application of accounting principles and financial reporting. I respectfully put forth, that this unfortunately is not the case and that history speaks for itself. It is for this reason in great part that the SEC, FASB and even the relatively new PCAOB have over time been forced into reducing the gray and establishing bright line rules. We are on the heels of the Sarbanes Oxley Act as a direct result of shockingly outrageous and criminal business judgment. The list of companies who have not experienced some type of financial misstatement is shorter than those who have. Strangely enough I have not heard of one occasion where these alleged accounting mistakes resulted in good financial news. These are not mistakes. These are aggressive accounting practices motivated by greed and we are now seriously considering opening the door to more by allowing even greater subjectivity for Corporate America's lawyers to argue in the defense of what is tantamount to criminal behavior disguised as business judgment. You must be kidding
Consider please why America is still the country most preferred for financial investment. Is it perhaps because our GAAP is also used to correct Corporate Americas behavior? Is it perhaps because these brighter lines help the SEC prosecute and enforce the law? Expanding business judgment will make prosecuting violations all the more difficult and without enforceable laws we are again opening the door to the unsightly human trait of greed. Why is our memory so short? Have we already forgotten why Sarbanes Oxley so rapidly became law?
Don't let the smooth talking advocates of IFRS sell you that dual reporting is overly burdensome. Preparing a reconciliation is overly burdensome? Time to prioritize. The greatest burden on Corporate America is Sarbanes Oxley. Focus our resources on effective and efficient implementation of SOX and continue to remove the subjectivity involved in accounting and reporting wherever possible or at least until our professionals demonstrate a commitment to the foundational principles of the accounting and legal professions.