Last week, I took part in the FEI Conference called "The World Is Moving To IFRS: Are You?" The keynote speaker was John White, director of the SEC's Division of Corporation Finance. While it would have been great to hear him discuss the SEC's IFRS "roadmap," it was not to be. The fact that it hasn't been released by this time leads one to believe that a rule won't be issued before the end of the SEC's current administration: it would be difficult to get a rule of this magnitude out for public comment and have it completed before the end of the year. Indeed, according to the FEI Blog, White's comments to the press after his speech indicated that "the roadmap will not be proposed rulemaking per se, although proposed rulemaking may be one of the signposts along the roadmap."

So, it may be along the lines of "speech GAAP?" Hmmm. We'll have to see how the roadmap gets positioned.

Back to the nitty-gritty. White raised the point that "... in the coming months as the IASB continues its work, including with regard to addressing possible gaps in IFRS, I look forward to the possibility that we in the U.S. will have some involvement in the standard setting process itself. And this is just one of the reasons that it is important for U.S. companies to be able to use IFRS, and maybe even be required to use IFRS. The thought here being that, in order for the U.S. to fully input in the standard setting process for IFRS, a portion of U.S. companies should be using IFRS. To the extent appropriate, our resources can be applied as IFRS are written and be persuasive or supportive of one position or another. But U.S. views and experience would likely be more persuasive if U.S. companies were using IFRS."

A good point - but one that makes it clear that U.S. companies have to be allowed to use IFRS. And if the IASB continues its work in addressing gaps in IFRS "in the coming months," and US companies would be more persuasive in addressing them if they were using IFRS, you have to wonder if there's going to be some hurry-up optionality in allowing companies to use IFRS sooner rather than later.

While that's a logical premise, it would be awfully difficult for investors to deal with. U.S. GAAP already has many choices of accounting treatments in it, and adding a broader layer of optionality will make comparisons even more difficult for them - especially if they are unfamiliar with the IFRS choices companies make.

White mentioned that implementation "will be a key consideration for the Commission." Here are the questions he raised "that should be part of the public debate about any U.S. transition to IFRS:" 

• Should all U.S. companies simply be mandated to start using IFRS in their SEC filings as of a certain date?
• Should there first be a period in which U.S. companies have the option to use IFRS in their financial statements, and if so, how long should such a period be?
• If there were such a period of optional use, would U.S. companies feel inclined to change to IFRS unless it were clear that mandated use of IFRS was in the foreseeable future?

My favorite idea (if we're convinced that IFRS is a high-quality set of standards, that is): mandate all companies to use IFRS as of a certain date, say 3 to 5 years from the date of the issued rule. No optionality in between, but be prepared to present all regularly-reported financial information on a retrospective IFRS basis when the switch gets flipped at that certain date. That would give companies ample time to develop the information as they go along; it will provide information to markets on a complete and consistent basis; and it will give investors, educators and practitioners time to evaluate their situations.