June 24, 2011
Toyota Motor Credit Corporation (TMCC) appreciates the opportunity to provide feedback to the SEC from the perspective of a preparer on the topic of incorporating IFRS into the financial reporting system for U.S. issuers.
TMCC is a domestic non-equity issuer that furnishes abbreviated disclosure pursuant to Form 10-K General Instruction I(1). All of TMCCs equity securities are owned indirectly by Toyota Motor Corporation (TMC), which is a reporting company under the Securities Exchange Act of 1934, as amended, and which has filed all the material required to be filed pursuant to section 13 thereof. TMC is currently planning to adopt IFRS as issued by the IASB for the fiscal year ending March 31, 2016. Under the current financial reporting system for U.S. issuers, TMCC, as well as any other domestic registrant whose parent company has adopted or is planning to adopt IFRS, is unable to report in accordance with IFRS and must report in accordance with U.S. GAAP. Therefore, TMCC will be required to maintain two separate sets of books, one under IFRS in order to submit results to TMC and a second under U.S. GAAP in order to file its financial statements with the SEC. We believe this requirement would unnecessarily strain the existing resources of accounting and financial reporting departments of such domestic registrants. This is especially true for domestic filers who, as in the case of TMCC, are issuers of debt with no publicly traded equity. As the SEC drafts guidance for the incorporation of IFRS into the U.S. financial reporting system, we request that you consider allowing domestic non-equity issuers that furnish abbreviated disclosure pursuant to Form 10-K General Instruction I(1) whose parent companies are foreign issuers that have adopted or are required by their home jurisdiction to adopt IFRS to likewise adopt IFRS for the purpose of filing such issuers financial statements with the SEC.