Tuesday, May 01, 2007

EU-US Framework Puts High Priority on GAAP-IFRS Equivalence

By James Hamilton, J.D., LL.M.

The SEC’s roadmap to the elimination of the need to reconcile IFRS-driven financial statements received a high-level boost as the European Union and the United States have adopted a joint framework on transatlantic financial integration that places a high priority on the equivalent recognition of US GAAP and international financial reporting standards in both jurisdictions without the need for reconciliation by 2009 or possibly sooner. The EU and US also expressed strong support for roadmap discussions between the European Commission and the PCAOB in the area of auditor oversight. The goal of the discussions is to quickly reach a point where the US and EU can rely on each other's auditing oversight systems and avoid burdensome and costly duplicative work and even conflicts of law.

More generally, the EU and US agreed to work towards greater regulatory convergence towards highest quality and most effective regulation and, where appropriate, mutual recognition in the fields of securities regulation. There is also a general agreed principle on increasing cooperation between EU and U.S. financial regulators under the dual goals of adequate investor protection and market integrity.

The agreed framework also promotes the smooth implementation of the Basel II framework for banks, notably to address transitional issues and minimize differences of implementation between the EU and United States.