Subject: File No. S7-20-07
From: Steven C. Dillard, CPA
Affiliation: Gradutate Student Middel Tennessee State University

November 12, 2007

With approximately 100 countries now requiring or allowing the use of IFRS, the globalization rate of international markets is sure to continue to increase. Companies wishing to take advantage of these international markets will benefit greatly from the use of IFRS. U.S. based multi-national companies already dealing with the increased cost of SOX compliance will benefit enormously from the reduced cost of using only one set of reporting standards. The improved comparability of financial statements across international boundaries is sure increase the amount of foreign direct investment flowing to the U.S., as well. These are just a couple of the many benefits that could and will arise from the use of IFRS. Allowing U.S. issuers to report in IFRS is the next logical step to maintaining our presence in the international markets.