Subject: File No. 265-24
From: James E woodward, Mr.

February 26, 2008

Dear Sir or Madam,

The work of the SEC Committee on Improvements To Financial Reporting is much needed and welcome. Attached is a paper that may be of help in the Committee's deliberations. Also included below are a couple of comments on the committee's preliminary suggestions:

1. The Committee's position that the FASB and related organizations need a stronger representation from the user/investor community is right on the money. This is a much needed and overdue change.

2. However, I believe that the Committee's recommendation to reduce and even eliminate acceptable alternative accounting policies is a mistake. Indeed, reducing allowable options will have some positive effects. However, a basic tenet of financial accounting is that good accounting essentially means a good match between the business and the accounting. Given the great and GROWING variety of types of businesses, types of business transactions, firm structures, etc., REDUCING allowable accounting options is an error (in my opinion). I think one of the major reasons for the growing popularity of IFRS vs. US GAAP is that IFRS is simple and allows more options than US GAAP. Thus, reducing allowable options in US GAAP will further handicap it vs. IFRS.

Thanks for your attention to these matters. Respectfully,

Ilia D. Dichev
Associate Professor of Accounting
Ross School of Business at the University of Michigan

Attachment: CEASA published version