I spent Monday through Wednesday attending the largest conference devoted to current events affecting financial reporting, featuring plenty of the SEC's staff - the ones who interact with the auditors examining the year end financials. And I'm wondering: when did the SEC become afraid of its own shadow? There seemed to be an overwhelming aura surrounding the SEC presenters, a kind of self-consciousness that they be careful to not "write GAAP" in the delivery of their speeches to the audience.

When this conference first began thirty-five years ago, the intent was to bring the SEC's thinkers and doers in front of a large audience of auditors, to discuss the problems they'd seen in filings with the audience. The intent was not to "speechify GAAP" - but to get the message out as to the problems they'd seen and describe how they handled it. The goal: to identify troublesome practice issues and tamp them down before they became pervasive by presenting them to the auditors who could do something about it. That's a worthwhile service to everyone involved in the financial reporting chain, from preparers down to users and the auditors in between.

That's not writing GAAP - that's being an effective regulator. (And don't forget that writing GAAP is something that the SEC is empowered to do.) Preventing problems through effective communication has always been at the heart of this conference. And this effective communication worked quite well long before the advent of Blackberries and the internet -  accounting firms responsible for keeping their SEC knowledge current seemed to get the message quite well by the state-of-the-art information distribution means, like overnight delivery and fax machines.

Now that there's virtually instant transmission of data, including the publication of all the speeches on the SEC's website at no charge to readers, critics are complaining about the dissemination of the comments in the speeches as being unfair. Absurd.

The comments of the SEC commentators were full of reminders of current GAAP, but missed the pithiness of years past when they described fact patterns that showed how a standard was misinterpreted or misapplied, and how they expected it to be remedied if encountered in practice by members of the audience. Instead, many of the commentators offered comprehensive reminders of where trouble might occur in the application of new accounting standards, rather than reporting on the known snafus they'd seen. Instead of warning registrants and auditors about problems they'd seen, it'slike they're wish-listing problems they hope don't happen. While there's value in that approach, there might be a lot more value in what they'd done in the past. Shouldn't regulators act like regulators, instead of acting like their walking on eggshells?