Subject: File No. 4-600
From: Michael R McMurtry, CPA

July 12, 2011

With regard to the staff paper, Exploring a Possible Method of Incorporation (of IFRS into the Financial Reporting System for U.S. Issuers) I am not in favor of this possible method. The ultimate result of this approach is allowing a U.S. "version" of IFRS, when for foreign issuers, the SEC requires IFRS as adopted by the IASB. A more preferable approach, in my opinion, is to allow, not require, companies to elect to use IFRS, possibly based on criteria involving its use by a particular industry or competitors, with a forward enough looking notice such as three or four years, and providing a US GAAP to IFRS reconciliation for a short period of time (one to three years). Such an approach allows companies to make a decision based on the economics of the decision and the utility of use by its investors. It also side steps issues of changing tax laws, etc. Given the SEC's allowing the use of IFRS by foreign issuers without reconciliation to US GAAP, this is a logical and cost-effective approach.