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There are three additional areas that I would like to address this morning where I think the Commission 's actions and possible actions are in the " sweet spot " of responsibly facilitating global investment activity : foreign deregistration ; the roadmap for consideration of acceptance of IFRS as a primary system of accounting without requiring reconciliation to U.S. GAAP ; and securities offering reform . When he arrived , the company was dominated by foreign soloists ; when he left , it had a complete ensemble comprising mostly native Russians . The main press release captures the excitement behind the announcement : " The Acrobat 8 product line introduces several major innovations in the areas of document collaboration , PDF content reuse , PDF forms , packaging of multiple documents , and controlling sensitive information . Some heavy users of financial data have staff solely dedicated to the burdensome process of translating paper into data by manually entering the information in periodic filings into a model in order to make comparisons . Since employee options have terms that usually extend for several years or more , we understand that some companies may be hesitant to use an implied volatility measure derived from traded options that typically have terms of 2 years or less . The show , whose tagline - - " Optimize Your Workflow with PDF Forms " - - indicates its focus , offers multiple starting times for East and West coast US participants and will be conducted online via Adobe 's Acrobat Connect service . While the proxy proposal does not affect foreign private issuers , Securities Offering Reform could have profound positive impacts for those issuers , which I will discuss in a few minutes . Overall , in my view , we ’ re seeing indications of positive responses from pension consultants when it comes to identifying , disclosing , or curtailing conflicts of interest in the advice that they provide to pension plan clients . This creates multiple problems for Adobe : less people will successfully create PDFs , and more people will be asking , " Where did my ' Create PDF ' button go ? But in areas involving internal corporate workings , such as audit committee listing standards and insider loans by foreign banks , the Commission has been appropriately flexible . He made multiple pirouettes on pointe , sustained balances and promenades and hops on pointe all obligatory for the ballerina . Finally , the Commission could consider whether there should be an easier and more effective process than exists today to make the Rule 12g3-2 ( b ) exception available to foreign private issuers who deregister and to make the resulting information better available to investors . Regulations and regulators should facilitate that very positive development . The staff has rejected this argument because there were multiple components involved in the transaction with the financing element causing the swap to have a fair value other than zero at inception .