Subject: File No. S7-20-07
From: Allan Leslie
Affiliation: Middle Tennessee State University

November 12, 2007

Allowing U.S. Issuers to prepare financial statements in accordance with International Financial Reporting Standards may be a positive step towards the IFRS's goal of global convergence. However, just allowing U.S. issuers to prepare statements in accordance with IFRS, discounts the mission of the FASB. The possible ramifications of allowing such an option are far too great to be given such freedom.

First and foremost, I am totally for convergence. I am pleased with the accomplishments the IFRS has made in the matter. Although I believe the SEC needs to take steps towards GAAP and IFRS convergence, I also believe that these steps should be consistent with the FASBs mission to improve financial accounting and reporting for the guidance and education of the public. If we, the U.S. investors, are still basing our decisions off of financial reports prepared in accordance with GAAP then the mission of the FASB is unscathed. However, if some companies are preparing public financial statements in accordance with IFRS, while others are preparing public financial statements in accordance with GAAP, then we have inconsistent reporting. This freedom of inconsistent reporting granted to the companies puts us, the investors, at a disadvantage as we are now more vulnerable to information asymmetry. Naturally, companies will prepare its financial statements in accordance to the standard that portrays their most optimistic financial position. To avoid this inconsistent reporting and potential asymmetric information, all U.S. issuers should either be required to prepare public information in accordance with IFRS or those issuers who choose to prepare their statements in accordance with IFRS should prepare another set of statements, in accordance with GAAP, to be utilized by the U.S. public.

The mission of the FASB is to establish and improve standards of financial accounting and reporting for the guidance and education of the public, including issuers, auditors, and users of financial information. Though global convergence is great, consistent reporting is even greater.