Subject: File No. 4-600
From: Daniel J Sullivan, CPA, MBA

June 29, 2011

Adapting GAAP to IFRS implies that IFRS is superior to GAAP.

I agree that convergance is the best approach.

I think that the US keeping GAAP, and the FASB adjusting GAAP with any portions of IFRS that are more persuasive than the current GAAP is the best policy.

Hopefully, gradually over time, the two bodies will move ever closer. IFRS can also move closer to GAAP.

An analogy is where the USGA, and The Royal and Ancient golf bodies have been moving their rules of golf slowly together.

Having a single world wide set of accounting rules, with fewer areas of alternative choices available to entities (such as no more LIFO), would make for greater comparative analysis of everyone.

Diversity is not a good thing in world wide accounting principles and rules.