Subject: File No. S7-27-08
From: Bryan McKinney

November 18, 2008

I think it's a step in the right direction to have required use of the International Financial Reporting Standards by U.S. issuers if they achieved the required milestones in the rule. The ultimate goal of enhancing the comparability of the financial information to investors is valuable given what seems to be reasonable amendments to the discussed regulations. Given the fact that capital markets are becoming more and more global, the idea of a single set of high quality accounting standards most definitely seems to enhance the comparability of financial information between US and non-US companies. This looks even more appetizing when one considers the corresponding increase in international investment opportunities for U.S. investors.