Subject: File No. S7-27-08
From: Martin Townsend
Affiliation: Instititute of Chartered Accountants in England and Wales

February 5, 2009

The proposed move to IFRS would be good for US companies in the medium to long term, by providing a level playing field with other companies internationally and by moving away from the prescriptive approach that we have with US-GAAP that is making financial statements so complex.

The uncertainty of whether the SEC will make the change to IFRS needs to be removed from the roadmap. Having the review of the situation in 2011 included is encouraging companies to delay making any decision on the assessment projects that need to start now in order to meet the 2014 proposed target date efficiently and without a mad panic such as was experienced with meeting the requirements of the Sarbanes-Oxley Act.