Subject: File No. S7-20-07
From: Joseph C. Jefferis
Affiliation: Whistleblower

June 9, 2008

GAAP is a complex set of accounting rules. When I passed the CPA exam in 1992, it was understood that America was capitalism's leader of the world. Since then, America's free enterprise system has come under attack. Our financial markets were attacked when terrorists blew up the world trade centers and today the financial markets are being attacked by the ologopy of oil producers.

As a Risk and Control Specialist for a global aerospace company, I blew the whistle on some very inappropriate accounting transactions. I sought protection under the Sarbanes-Oxley whistleblower protection clauses through OSHA. OSHA is charged with enforcing the law. The reality of my ordeal is that OSHA is unable to enforce the law.

I oppose the movement to IFRS because it will create foreign sovereign bodies who decided right and wrong. While enforcing Sarbanes-Oxley is difficult, I see no tolerance or expectation for oversight and protected activity if IFRS is adopted.

You interest in my efforts to blow the whistle regarding a $9.3M accounting irregularity is being requested.

CASE NO: 2007-SOX-00075

In the matter of:

Joseph C. Jefferis, Complainant
v.
Goodrich Corporation, Respondent
Before: Joseph E. Kanes, Administrative Law Judge

The disposition of my complaint effectively blocked any investigation from occurring. This example is precisely how I view disputes under IFRS to be handledby the few and for the elite.

Where is the role for the average Joe in understanding and reporting wrongdoing in IFRS?