Subject: File No. 4-600
From: Rodney Sprenger, CPA

June 6, 2011

Re: Convergence and Global Accounting Standard

My experience comes from many years in both the public and industry accounting fields so I have basis for my comments. I disagree with the approach of converging U.S. Accounting Standards with foreign standards in that U.S. Standards have sound well developed basis, provided there is consistent application and adherence to regulation and disciplinary action, while foriegn standards if you look closely are mirrored for the most part around U.S. Standards.

The U.S. has, for the most part, remained a dominant and timely position in the development and implementation of appropriate accounting standards based on current accounting trends.

I therefore severly question why there are considerations being made to subject sounds U.S. Accounting Standards to any dilution.

Respectfully Submitted,
Rodney C. Sprenger, CPA