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

November 28, 2008

I do not agree with SEC's preparation for adoption in accordance with the International Financial Reporting Standards (IFRS) if foreign corporations publicly offered at US stock markets are strictly managed to comply with the adoption manner.
Some countries' accounting rules and regulations are about to be IFRS-compliant in convergence manner. It is known that EU recognizes the convergence manner as sufficient with IFRS.
Also, it is supposed that differences between adoption and convergence, even if they are slight, make accounting jobs complex without resolving parallelism of multiple rules and regulations for disclosure. It is a serious cost-pushing matter for global enterprises' businesses.