1.On September 26, 2007 a representative from Merrill Lynch presented a comment letter in regards to the SEC 33.8818 proposal to end the reconciliation requirement for foreign companies to comply with GAAP rules, standards and guidelines when issuing financial statements. Merrill Lynch applauds the decision and it is easy to see why. According to the comment letter Merrill believes that the reconciliation requirement has been an impediment to foreign companies that costs Merrill Lynch (and many other financial firms) millions of dollars in revenue each year. In the letter Merrill Lynch states that there have been a record number of de-listings on the NYSE due to this requirement. Considering the fact that to list a stock on the exchange costs a company approximately $35,000 per year, but that the reconciliation requirement can cost the same company millions in accounting fees, Merrill's point is well taken.
             2.On September 26, 2007 a representative from Goldman Sach presented a comment letter in regards to the SEC 33.8818 proposal to end the reconciliation requirement for foreign companies to comply with GAAP rules, standards and guidelines when issuing financial statements. Goldman's comments echoed Merrill's comments in regard to the enthusiastic support for acceptance of the proposal. Goldman's comments further illustrated the point that there seemed to be a natural convergence of GAAP and IFRS requirements, and there were a number of countries (besides the U.S.) that had already made the decision to accept the IFRS standards as well as quite a few countries in the process of doing so.
             3.The SEC 33.8818 proposal to no longer require foreign companies to reconcile their financial statements according to GAAP rules and standards is a proposal that portrays just how the rest of the world has caught up to the United States in regards to financial markets. No longer can the U.S. be assured that foreign co
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