Subject: File No. 265-24
From: Sherman L Rosenfield, CPA
Affiliation: Self employed Concurring Reviewer for local CPA firms

October 13, 2007

In my opinion, there are several existing pronouncements- or parts thereof- or SEC requirements- that probably no longer provide simple cost/beneficial information to users. Those pronouncements should be considered for elimination. Those topics are:

109: Deferred Income Taxes- Consider eliminating in its entirety

115: Investments- Consider eliminating the multiple portfolio approach and run all holding gain/losses through the bottom of the Operating statement (as is currently being done with NFP's)

133: Derivatives ( all related amendments, interpretations, etc.- Consider elimination this failed experiment

SEC requirement to quote specific authoritative references by number or name (i.e 109 or 115)- Consider eliminating