Compliance Update

On Friday, November 14, the SEC posted the proposed rule which provides a roadmap towards requiring the use of International Financial Reporting Standards (“IFRS”) as issued by the International Accounting Standards Board (“IASB”).

The proposed rule sets forth several milestones that lead to the use of IFRS by U.S. issuers in their filings with the SEC beginning in 2014. These milestones relate to:

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improvements in accounting standards;

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the accountability and funding of the IASC Foundation;

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the improvement in the ability to use interactive data for IFRS reporting;

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education and training relating to IFRS;

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limited early use of IFRS where this would enhance comparability for U.S. investors;

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the anticipated timing of future rulemaking by the Commission; and

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the implementation of the mandatory use of IFRS by U.S. issuers.

The Commission is soliciting feedback and encourages comments on a list of questions in the proposed rule. The Commission will accept comments on the proposed rule for 90 days following publication in the Federal Register. You can submit comments by:

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using the online comment form;

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sending an e-mail to rule-comments@sec.gov (Include "File Number S7-27-08" in the subject line);

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using the Federal eRulemaking Portal at http://www.regulations.gov; or

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mailing comments (in triplicate) to:

Florence E. Harmon

Acting Secretary

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-1090

To read the proposed rule on the IFRS roadmap, please visit http://www.sec.gov/rules/proposed/2008/33-8982.pdf.