Date:    05/24/2000  10:58 PM

Subject: File No. S7-04-00

Mr Jonathan G Katz
Secretary
Securities & Exchange Commission
450 Fifth Street NW
Washington DC 20549 - 0609
USA
     
24 May 2000
     
     
RE: File No. S7-04-00
     
Dear Mr Katz,
     
I apologise for the brevity of my comments, but, due to time constraints, I 
am unable to provide a detailed submission on your concept release. My 
comments below are confined to a couple of issues and I hope they 
contribute in a constructive manner to your deliberations. I am a 
journalist and I spend all my time writing about accounting and corporate 
regulation for nine different organisations both here in Australia and 
overseas.
     
The accounting framework offered by the IASC does deal with a broad range of 
issues and, if the IOSCO endorsement is any guide, it provides a foundation 
for the IASC and national standard setters to build on and refine the 30 
pronouncements focused on by the global regulators. However, there is the 
question of what to do in areas where the IASC does not have a pronouncement 
or where a pronouncement was excluded from the core standards project 
because of its industry-specific nature. It is important that each 
jurisdiction enforce its own requirements until the IASC fills the gaps in 
its framework. To leave a gap in guidance on accounting matters because the 
IASC may deal with it soon would be irresponsible. This would be tantamount 
to not accounting for something because of the absence of an answer from 
within the IASC framework. Domestic GAAP must apply until fresh product 
emerges from the IASC so the flow of information to investors is not 
constrained in any way.
     
IOSCO's assessment report has a number of concerns from one or more members 
of the relevant IOSCO working party that suggest the IASC framework is on 
its way to becoming a stronger basis for an international reporting 
language. I believe the endorsement was a positive step but that 
improvements, particularly in the area of financial instruments, are 
necessary in order for the standards to be regarded as rigorous.
     
Enforcement of any set of IASC standards will be crucial. Only uniform 
enforcement in all jurisdictions can bring about an appropriate 
interpretation of the standards. It is convenient to argue - as some have 
in Australia - for international accounting standards to be use in each 
country, but they often ignore the enforcement element.  There will be no 
consistency in the way IASC standards are applied globally unless there is 
an agreement from all nations to enforce the rules with equal vigour. A 
failure to enforce the standards uniformly defeats the purpose of having a 
single language and create a differential reporting environment between 
jurisdictions or even between entity accounts within the same jurisdiction.
     
I want to thank you for the opportunity to respond to your concept release 
and I hope to be able to provide some further detailed comments in the future.
     
Kind Regards
Tom Ravlic
     
     
Tom Ravlic
Freelance Journalist specialising
in accounting and corporate law
5 Goulburn Place
Clayton South 3169