US comment Letter Writing to the IASB and Evolving SEC Views on the Use of IFRS

ABSTRACT This paper investigates drivers of US lobbying on the International Accounting Standards Board (IASB) before, during, and after the Securities and Exchange Commission’s (SEC) active consideration to adopt International Financial Reporting Standards (IFRS). Examining comment letters (CLs) for 148 IASB proposals from 2001 through 2014 finds that while a variety of US stakeholders lobbied, the response rates are low. CL writing in total and by preparers significantly increased during the peak of SEC interest (2007–2010), but afterwards significantly decreased. US writers focus more on key issues rather than responding to proposals earlier in the IASB’s due process. US writers lobbied more about topics also on the Financial Accounting Standards Board (FASB)’s agenda and larger US preparers were more likely to write CLs and write them more frequently than smaller preparers. Overall, response rates are associated with the likelihood that US stakeholders would need to comply with IFRS.