November 13, 2007

Ms. Nancy M. Morris
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549–1090

Re: File Number S7–20–07 – Concept Release on Allowing U.S. Issuers to Prepare Financial Statements in Accordance with International Financial Reporting Standards

Dear Ms. Morris:

The Bank of New York Mellon appreciates the opportunity to comment on the U.S. Securities and Exchange Commission’s Concept Release.

We strongly support the proposed measure, which would harmonize accounting standards worldwide. From the perspective of our position at the center of the global capital markets, we are confident this development would enhance the competitiveness of U.S. firms operating in an increasingly global business environment.

In addition to greatly improving the efficiency and standardization of accounting and reporting processes, the creation of a single global accounting standard would help simplify cross-border acquisitions and improve investment flows by creating enhanced comparability for investors. As one of the world’s leading global financial services companies operating in multiple jurisdictions, we feel confident this would benefit U.S. financial institutions.

We urge the timely adoption of the proposed change.

Sincerely yours,

Robert P. Kelly
Chief Executive Officer
The Bank of New York Mellon