Disclosure Standards project, it is quite likely that the SEC would propose changes
to Form 20-F, and, as it did with the adoption of the nonfinancial statement Interna-
tional Disclosure Standards, apply the changes to all non-U.S. companies accessing
the U.S. public markets, not just those involved in cross-border equity offerings.
Even within that context however, the SEC may waive only some of its requirements,
require supplemental information in addition to IAS financials, impose additional re-
quirements or reconciliation for particular industries, or remove the reconciliation re-
quirement only for issuers that meet certain tests of size, liquidity, listing, or disclo-
sure history.
If the SEC does decide to accept financial statements prepared in accordance with
IASs, non-U.S. companies filing registration statements can still expect to receive
substantial SEC comments on their financials in the review process. Just as the SEC
rigorously tests financial statements prepared under U.S. GAAP, and enforces the
standards established by FASB, the SEC will enforce IASC principles and interpre-
tations when reviewing IAS statements.
(e) Other SEC Initiatives. Other than the participation in the aforementioned multi-
lateral measures, the SEC has been involved in a number of bilateral efforts to inte-
grate the capital markets. The SEC has assisted or promised to assist many emerging
markets in formulating and/or streamlining their securities regulations in conformity
with international standards. The SEC’s Office of International Affairs (OIA) has pri-
mary responsibility for the negotiation and implementation of information-sharing
arrangements, and for developing legislative and other initiatives to facilitate interna-
tional cooperation. The OIA coordinates and assists in making requests for assistance
to, and responding to requests for assistance from, foreign authorities. The OIA also
addresses other international issues that arise in litigated matters, such as effecting
service of process abroad and gathering foreign-based evidence under various inter-
national conventions, freezing assets located abroad, and enforcing judgments ob-
tained by the SEC in the United States against foreign parties. In addition, the OIA op-
erates in a consultative role regarding the significant ongoing international programs
and initiatives of the SEC’s other divisions and offices. Since August 1993, the OIA
has been responsible for coordinating the SEC’s technical assistance program for
training and advice in countries with developing securities markets. The OIA also con-
sults with and provides technical assistance to other federal agencies regarding trade-
related issues relevant to the regulation of securities markets in the United States.
The SEC has signed comprehensive Memoranda of Understanding (MOUs) for
consultation and cooperation in enforcement-related matters with a number of regu-
lators. These MOUs usually entail providing consultation, technical assistance, and
mutual assistance of exchange of information. The SEC International Institute for Se-
curities Market Development (the SEC Institute) is the SEC’s flagship technical as-
sistance program. The SEC Institute is a two-week, management-level training pro-
gram covering a full range of topics relevant to the development and oversight of
securities markets. The SEC’s technical assistance efforts in Eastern Europe have in-
cluded sending SEC staff as advisers to several countries in the region under a pro-
gram funded by the United States Agency for International Development. The SEC
has also participated in a number of short-term assistance projects for the countries
of Latin America and the Caribbean, as well as several countries in other regions. The
SEC also invites foreign securities regulators to participate in the SEC’s Annual En-
forcement Training Program held in the fall.
14 • 22 GLOBALIZATION OF WORLD FINANCIAL MARKETS