Mr Johnathan J. Katz
Securities and Exchange Commission
450 Fifth Street, NW
D.C. 20549-0609
United States of America


Paul Chisnall

Direct Line: 020 7216 8865
Direct Fax: 020 7216 4365

23 May 2000

Reference: file no. S7-04-00

Dear Mr Katz

SEC concept release on international accounting standards

We fully support the global harmonisation of accounting standards and believe that the IASC core standards provide an acceptable platform for such harmonisation. As the Commission's release makes clear there are a number of unresolved issues concerning the enforcement of IASs. In our view, however, the Commission's existing enforcement powers mean that these issues need not delay the acceptance by the Commission of financial statements prepared in accordance with IASs without reconciliation to US GAAP.

We would also urge the Commission to contribute to the IASC's revision of IAS 30 `Disclosures in the Financial Statements of Banks and Similar Financial Institutions' and concurrently to review Industry Guide 3 with a view to aligning it with the revised IAS.

Yours sincerely

Paul Chisnall