Now that I’ve weighed in with some insights on the IFRS comment letters the SEC received, I’ve been asking IFRS experts what they think.

D.J. Gannon, national leader of Deloitte’s IFRS Center of Excellence, put it succinctly. “The key theme coming from the comment letters is how to achieve a single set of high-quality globally accepted accounting standards,” he told me. “This is the ‘convergence vs. adoption’ issue.”

The SEC’s road map contemplates eventual adoption of IFRS for U.S. public companies beginning in 2014. Although some folks support this, others have argued that convergence (a process currently taking place between the FASB and IASB) is the better route.

Gannon identified a few other important themes running through the comment letters.

Besides the adoption vs. convergence issues, another item in the comment letters relates to whether the proposed “milestones” in the road map should be viewed as gating conditions, to be completed before any decision is made on mandatory adoption, or whether such items are more implementation issues, according to Gannon.

“In terms of individual milestones, many have emphasized the importance of enhancing the funding and accountability of the International Accounting Standards Committee Foundation to ensure the independence and objectivity of the IASB,” he adds.

He also points to a number of comments on the timeline for mandatory adoption of IFRS, and more specifically the need for allowing companies sufficient time between when the SEC decides to require IFRS and the date of transition (which is the opening balance sheet date).

Finally, Gannon notes that a number of letter writers took the proposed road map to task for including several disincentives attached to the potential for early use of IFRS.

These disincentives include the possibility of early adopters of IFRS having to revert back to U.S. GAAP, the proposed two years of comparative IFRS financial statements in the year of adoption, and the proposed alternative of an ongoing reconciliation between IFRS and U.S. GAAP. ###