Subject: File No. S7-27-08
From: Shawn S Fahrer
Affiliation: Accounting Student, Queensborough Community College (CUNY)

February 24, 2009

Re: File Number 87-27-08
Education and Training Section 4, part III--

If IFRS becomes, in effect, "the law of the accounting land", it is clear that "IFRS supplements to and IFRS content in accounting textbooks" as in footnote 67 would clearly be insufficient for undergraduate AND graduate accounting education going forward. In fact, it would appear that most textbooks would have to be totally rewritten (by writers who may or may not be familiar enough with IFRS to do the subject justice).

Usually what happens (from what I've observed) is that textbooks have a basic framework regarding their subject matter, and changes are made in little bites as appropriate (based on FASB or SEC pronouncements) which justify a new edition every year or so. From what little I know about IFRS, it would require far more than bits and pieces changes to most US accounting textbooks (since it is NOT GAAP). Costs of such rewrites would also add to the (already very high) costs of accounting textbooks.

The road map doesn't address these dual factors of potentially higher cost (and lower quality) US accounting textbooks. In fact, it gives education a very short shrift (filling approximately TWO pages out of 165, or approximately 1.2% of the original road map).

This is unacceptable, considering the need for high quality IFRS education in the near future for students like myself. After all, if we are not properly trained to understand financial statements prepared using IFRS, potential employers won't want to hire new graduates, and we'll be on the unemployment line.

As a result, before we plunge headlong into the IFRS cliff, all concerned entities MUST consider the startup costs not just for business entities, but academic entities as well-- costs in terms of time AND money-- all this for a potentially inferior product.

Professors would have to be retrained (the older the professor the harder this may be). Then THEY have to master it enough to train STUDENTS properly. If the US is going to switch to IFRS by 2014, we don't have much time to tackle this problem.

re: General Comments about an IFRS Transition from GAAP

Considering that we are in a deep recession (and may not be able to AFFORD to switch accounting standards in the middle of this recession)-- the idea of such a change sounds as bad as changing generals in the middle of a battle. We should wait until the battle (recession) is over before we should make a change in generals. Similarly, the U S should HOLD OFF IFRS transition as long as possible. Once (if) our economy improves, then and ONLY then can IFRS be taken off the back burner for such a GAAP to IFRS transition.

This would help all concerned (US business, educators AND students) who are going to have enough of a hard time with an economy running under GAAP accounting rules.