Subject: File No. 4-497
From: KIT WHYE CHAN, FCPA Australia

February 23, 2005

The enactment of Sarbanes-Oxley Act is certainly unprecedented and its enforcement will be watched by many countries like Singapore.
Corporate governance rules put in place without legal enforcement certainly will not prevent fraudulent financial reporting or mistatements from occurring.

The recent corporate failures in Singapore, eg China Aviation Oil and Accord Customer Care Services, demonstrate that legal enforcement on internal control and risk management must be considered rather than imposing corporate governance rules. Although many argue that the costs of imposing SOX rules outweight its benefits, it is worth setting it in motion to assess the effectiveness of the enforcement.

More needs to be done, however, to clarify the details of how to ensure that SOX 404 is being satisfactorily complied. Many have adopted or will be adopting the COSO framework on internal control. The corporate world may need to be exposed to more of such framework to tailor to different needs and different company sizes. If there are more framework that are simple and easy to use, then the cost of compliance could be significantly reduced.

Corporate America is quick enough to set Sarbanes-Oxley in motion and I believe very soon the world will follow suit if there is a degree of success in its implementation and the tolerance in corporate failures is substantially reduced. I strongly believe that a sound internal control and financial reporting system will significantly enhance shareholders value.

Kit Whye Chan