This Article argues that the European Union (“EU”) has been instrumental in moving the United States (“U.S.”) Securities and Exchange Commission (“SEC”) from a policy of national treatment of foreign (non-U.S.) issuers to a policy of mutual recognition of financial disclosure accounting standards based on convergence between U.S. accounting standards and international accounting standards. Further, future initiatives based on a national treatment model are under consideration by the SEC. At the same time, progress on the road to mutual recognition has been made possible by SEC influences on the EU, leading to securities regulation reform in the EU, and greater convergence between U.S. and EU securities regulation.
Roberta S. Karmel,
The EU Challenge to the SEC,
31 Fordham Int'l L.J. 1692
Available at: http://ir.lawnet.fordham.edu/ilj/vol31/iss6/5