Subject: File No. S7-20-07
From: Zhen Zhang
Affiliation: Middle Tennessee State University

November 13, 2007

Financial information should be useful for users to make decisions. To be useful, financial information should be comparable and transparent, as well as reliable and consistent. From this standpoint, it is good to converge GAAP AND IFRS.

We cannot require accountants and investors outside the U.S. to be familiar with U.S. GAAP. The downside of this is that the cost of investment in U.S. companies increases which makes financial markets in other parts of the world more attractive to investors. Moreover, it is also more costly for U.S. companies to invest abroad.

In my opinion, the idea that the foreign private issuers financial statements could be prepared in accordance with the English version of IFRS will be helpful for attracting foreign companies to the U.S. market.