Comments on Proposed Rule: Acceptance From Foreign Private Issuers of Financial Statements Prepared in Accordance With International Financial Reporting Standards Without Reconciliation to U.S. GAAP

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Date Received
Date Letter Type Commenter Name
Public Comment Renato Fassbind, Chief Financial Officer, and Rudolf Bless, Chief Accounting Officer, Credit Suisse Group
Public Comment Richard Whiting, Executive Director and General Counsel, Financial Services Roundtable
Public Comment Robert Traficanti, Vice President and Deputy Controller, Citigroup Inc.
Public Comment Russell Read, Chief Investment Officer, CalPERS
Public Comment Sullivan and Cromwell LLP, London, United Kingdom
Public Comment Brent Kobayashi, Masters of Accounting Candidate, University of Hawaii at Manoa, Shidler College of Business
Public Comment Daniel T. Kay, MAcc candidate, University of Hawaii, Manoa
Public Comment Hoa Nhu, Graduate Student, Master of Accounting, School of Accountancy - Shilder College of Business Administration, University of Hawaii at Manoa
Public Comment Sam Ooka
Public Comment Terry Warfield, PhD, Associate Professor of Accounting, University of Wisconsin - Madison
Public Comment Alexis L. Serfaty, Policy Director, European-American Business Council, Washington, District of Columbia
Public Comment David A. Lifson, President, New York State Society of Certified Public Accountants
Public Comment Deloitte Touche Tohmatsu
Public Comment Denis Duverne, Chief Financial Officer, AXA; Peter Voser, Chief Financial Officer, Royal Dutch Shell; and Clive Standish, Chief Financial Officer, UBS AG
Public Comment Donna J. Fisher, Director, Tax and Accounting, American Bankers Association
Public Comment FW M. Starkie, Group Vice President & Chief Accounting Officer, BP p.l.c.
Public Comment Helen A. Weir, Group Finance Director, Lloyds TSB Group plc, London, United Kingdom
Public Comment Ken Lever, Chairman, The Hundred Group - Financial Reporting Committee
Public Comment Klaus-Peter Naumann, Chief Executive Officer, Institut der Wirtschaftsprüfer in Deutschland
Public Comment Members of EALIC and Members of UNIQUE
Public Comment Michael Smith, Group Chief Accountant, Unilever plc
Public Comment Pascal Desroches, Chair, Financial Reporting Committee, Institute of Management Accountants
Public Comment Tong Yu, Paul, Weiss, Rifkind, Wharton & Garrison LLP, on behalf of Mitsubishi UFJ Financial Group
Public Comment Jane Diplock, A0, Chairman,Securities Commission
Public Comment Peter Martin, CA, Director, Canadian Accounting Standards Board
Public Comment B. Craig Owens, Executive Vice President & Chief Financial Officer, Delhaize Group
Public Comment Denis Duverne, Chairman, European Insurance CFO Forum
Public Comment Dr. Peter Baumgartner, Chair Executive Committee and Dr. Jan Atteslander, Member Executive, SwissHoldings
Public Comment Katrin Burkardt and Silvia Schutte
Public Comment Ian Harrison, Director, London Investment Banking Association

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-13-07
Release Number
33-8818
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