Subject: File No. S7-27-08
From: Margery L Piercey
Affiliation: CPA, Wolf Company, P.C.

February 3, 2009

There is a significant amount of investment in people products and RD needed to get this economy back on its feet, and while I am hopeful that some immediate actions by the government will jump start the recovery or at least prevent the bottom from falling out, I think the recovery is a long-term project. I hate to see businesses distracted and resources spent on IFRS. Some point fingers at fair value accounting as a culprit for the financial crisis we are in. I think it contributed - not because fair value accounting is wrong, but because of what it exposed financial irresponsibility by consumers and corporations. (But that is another conversation.) I think another contributor was Sarbanes-Oxley. The dollars that have been spent - the resources diverted from investment in RD, forward-thinking resources, and information security are enormous. Just imagine if the car companies had invested in RD what they spent on SOX compliance over the last five years or where we might be if banks and credit card processors might have spent their SOX dollars on information security. I'm not implying that SOX doesn't have its redeeming attributes - it does. IFRS has redeeming attributes too, but now is not to the time to add more cost and near-term confusion to the capital markets when time, energy and dollars need to be spent on the business at hand. Believe me, IFRS will be great for my business, but I'm looking at the much bigger picture here.