refer to them as the bilateral approach, the multilateral approach, and the international approach.
Let me start with the bilateral approach, under which regulators in
one country enter into bilateral arrangements as to accounting
harmonization with regulators in another country. An example of this
approach is the proposed bilateral disclosure system between Canada
and the United States pending at the SEC. 19/ The advantage of the
bilateral approach is that it may be faster and easier to implement than
disadvantage is that, as more and more separate bilateral agreements
are entered into, requirements under one bilateral agreement may differ
from those under another bilateral agreement, thereby perpetuating
rather than reducing accounting disparities.
The second approach is cooperation on a regional basis ••-
multilateralism. The best example of this approach is in the European
Economic Community, which has taken a number of significant steps,
inclUding some involving accounting, to facilitate capital flows among its
member states. For example, the EEC has issued a directive on mutual
recognition of member states' prospectuses and related financial
19/ ~ 1990).
Securities Act Release No. 6879, 55 FR 45896 (October 31,