Subject: File No. S7-20-07
From: Rachel A Kelley
Affiliation: Graduate Student, Middle Tennessee State University

November 12, 2007

November 12, 2007

Numerous companies choose to list on stock exchanges outside of their home country. Various countries have adopted the use of International Financial Reporting Standards (IFRS). It takes time, money, and effort to report financial statements using different methods in order to remain compliant with rules and regulations of various countries. Issuers in the United States (U.S.) should be allowed to report their financial statements using IFRS.

We live in a global, economic society. Americans cannot afford to believe we are the supreme financial and economic power of the world anymore. Foreign issuers are shifting from U.S. stock exchanges, such as the New York Stock Exchange (NYSE), and choosing to be listed in other countries to avoid the many rules and regulations of the Securities and Exchange Commission (SEC). Several countries are adopting the use of IFRS and the U.S. needs to catch up in this area. Following the crowd is not always the right path, but the SEC should implement what is best for the U.S. economy.

Compiling financial statements in accordance with more than one country's standard can be costly to issuers wishing to list on more than one stock exchange in different countries. This could be considered a deterrent to companies who wish to be listed on the NYSE, for example. Issuers will also be required to hire extra accountants who are proficient with IFRS.

The SEC should proceed and allow U.S. issuers to prepare their financial statements in accordance with IFRS. The principles-based IFRS differ from the rules-based generally accepted accounting principles used in the U.S. (U.S. GAAP) and if the SEC allows issuers to use IFRS, then issuers should strictly follow the standards without adapting them for U.S. GAAP. The SEC should still retain enforcement policies regarding correct and fair reporting of U.S. issuers to protect investors at home and abroad.