Subject: File No. 4-564
From: Michael Ramos, CPA

August 1, 2008

In the push to IFRS adoption there has been very little public discussion about the pros and cons of adoption. There is a general perception within the profession and the business community that IFRS is imminent, and that those of us who advocate proceeding more slowly are obstructing progress. I thank you for holding these hearings and hope that they are a start toward a productive public dialogue.

Historically, financial statements have been viewed as necessary for the benefit of investors, creditors and other decision makers. It seems clear how the big CPA firms, company management and accounting consultants will benefit from IFRS adoption.

What remains to be answered is how US investors will benefit from adoption, how the financial statements they use to make decisions will remain comparable, and how IFRS will provide a presentation of the company's financial performance and condition that is as fair and transparent as that currently provided by US GAAP.