Subject: File No. S7-27-08
From: Yaz Fujita, MBA
Affiliation: IT Consultant, specialized in finance accounting

November 27, 2008

SEC should not deny convergence disclosure manner of foreign enterprises whose countries' accounting rules and regulations are eager to be compliant with the International Financial Reporting Standards (IFRS) so that they can reduce huge efforts of settlement procedures that sometimes weaken corporate business performance.
Basically I agree with SEC's roadmap for preparing adoption with IFRS. It is profitable for global enterprises publicly offered in US stock markets since they will be able to disclose their financial statements at any market in the world in the same procedures in equivalent rules regulations.
However, I will not agree with it if SEC is about to restrict disclosure procedures which are not strictly compliant with IFRS, even they are constructed in convergence manner. If an enterprise in some country other than US where convergence manner is about to be adopted is managed to disclose its financial statements in entire manner completely adopted with IFRS, the parallelism of disclosure effort will not be reduced, or will be more complex to resolve numbers of slight differences between convergence and adopted manners.