Subject: File No. S7-24-06
From: Oscar Macedo

December 29, 2006

Dear Sirs,

I would like to remark that in the proposed guide, specifically in the section III point number 1 B ("Identifying Controls that Adequately Address Financial Reporting Risk"), never is mentioned that one identified control for a financial reporting can cover more than one key risk.

I consider than an efficient selection of controls, based on the criteria that one control can cover more than one key risk, could help to reduce the efforts for the evaluation of the effectiveness.

Kind Regards,

Oscar Macedo