Subject: File No. S7-27-08
From: Philip Berman
Affiliation: CFO, DAS Consulting LLC

April 20, 2009

I would argue that the "PROPOSED ROADMAP..." is in fact a roadmap back to GAAP in its infantile state. Why would the SEC abandon a system that has been years in the making in favor of a system that is only now in its 'gestational' stage? Please consider the argument that GAAP has become the monstrosity it is today due to unbridled litigation, a profession that wants to pass judgment on financial statements but does not care to bear risk or to defend their arguments, and an investing community that looks to place blame on anyone but themselves if a company fails in its efforts at profitability and increasing shareholder value. Those same forces are at work today and will ultimately bring IFRS to the same state that GAAP has become. Lets FIX GAAP, and get out there to promote our generations of hard work to gain acceptance rather than to 'toss in the towel' and start over. Lets teach investors that there is no practical way to make accounting a perfect science, teach accountants/auditors that the road to successfully reporting the condition of a company is not to shoehorn everything into one or more FASB's that can be cited as a safe-harbor in a court of law, lobby for the necessity of insulating corporate officers and their auditors from action when there is no intention of malice, and lets bring back the creative thinking that has developed the most sophisticated markets and economy in the world. With apologies to Madam Chairwoman, the SEC needs to 'man-up' and admit past mistakes, fix what we've got, and get out there and sell it to the global marketplace. What you're doing is tantamount to firing the 50-year-old in favor of the 21-year-old because you want to 'freshen things up'. We don't need a "Roadmap" to go back to where we came from, we need "GPS" to get to new destinations.