Subject: File No. 265-24
From: Michael P Krzus
Affiliation: Partner, Grant Thornton LLP and President, The Enhanced Business Reporting Consortium

June 19, 2008

Additional comments attached.

The Enhanced Business Reporting Consortium (EBRC) respectfully submits the attached EBRC-Knowledge@Wharton Business Reporting Survey: Part Two in response to the Subcommittee Reports of the SEC Advisory Committee on Improvements to Financial Reporting (CIFiR) dated May 2, 2008. The EBRC was founded by the AICPA, Grant Thornton LLP, Microsoft Corporation, and PricewaterhouseCoopers LLP in 2005. EBRC and Knowledge@Wharton, the online research and business analysis journal of the Wharton School of the University of Pennsylvania, joined forces to study key issues in, among other things, business reporting, key performance indicators, intellectual capital and intangibles.

Our most recent survey was launched on May 28, 2008 and over 475 people responded as of June 19, 2008. A few critical findings from the survey (copy attached) that are directly relevant to the work of the Delivering Financial Information Subcommittee of CIFiR follow:

1. 74% of the respondents believe that companies should disclose key performance indicators, intangibles, value drivers, intellectual assets in addition to financial statements and notes
2. 74% believe that standardization of key performance indicators, intangibles, value drivers, intellectual assets should be pursued within industry sectors to facilitate comparability
3. 51% believe that standardization should be done by industry groups comprised of companies, industry analysts and investors

The EBRC respectfully submits that we can assist CIFiR in meeting its mission to enhance business reporting for the benefit of the capital markets. We are prepared to provide additional material further explaining our position if that would be helpful. Please contact Mike Krzus at 312-602-8029 with any questions or requests. Thank you for the opportunity to share our views.

Respectfully Submitted,
The Enhanced Business Reporting Consortium