Subject: File No. S7-27-08
From: Alfred M. King

November 18, 2008

Responses to Request for Comment on Page 48 of your release:

1. Agree that one set of standards is probably preferable to two sets. It is not at all clear that IFRS is superior to U.S. GAAP. Therefore why not have IASB adopt U.S. GAAP as you indicate FASB should adopt IFRS? Just one example. Under IFRS companies can revalue assets upwards. Do we really want companies to manage earnings in this way? I am in the valuation business, with 40 years of experience, and it is abundantly clear that valuation is far from an exact science. Permitting revaluations opens the door to real abuse.

My second point deals with the cost of transition. If I understand the proposal, that requires three years of audited IFRS statements, companies would have to run dual books for three years, pay for duplicate audits, internal controls and so forth. Before moving forward you should obtain detailed cost estimates from companies of what costs will be incurred, and then develop a cost/benefit analysis.

Is there any evidence that shareholders and creditors (the audience for financial statements) want or need a switch to IFRS? If there is such evidence you should publicize it as soon as possible. Mandating a switch to IFRS from GAAP is going to require massive resources, at a time when the economy is none too strong, and with no substantive arguments in favor of a switch I believe this idea should be scrapped.