Subject: File No. S7-27-08
From: Yasushi Fujita, MBA
Affiliation: Consultant

November 28, 2008

First, it is astonishingly reasonable if we are able to perform disclosure for several countries' stock market in the same standard i.e. IFRS.
Second, we should notice slight difference occurred by two manners to making every country's disclosure policy compliant with IFRS, i.e. between "adoption" and "convergence."
Third, thus, we expect IFRS reducing efforts and costs to perform disclosure processes for multiple stock markets e.g. NYSE, NASDAQ, LSE, TSE, and so on. If it is not realized because of parallelism of "adoption" and "convergence", it will be meaningless and still complex.
Fourth, we should know that EU has already recognized not only the "adoption" manner but also the "convergence" one as IFRS compliant. Any policy cannot deny this fact.