FEI believes that US capital markets are better served by having foreign registrants use an investor-oriented accounting model like IAS in the primary financial statements rather than providing bits and pieces of financial data that reconcile to US GAAP supplementally. We also believe that the expanded use of IAS in world markets, which is much more likely to occur with SEC acceptance in the US, will further improve the comparability of financial results between US and foreign companies. We would therefore support the Commission's acceptance of IAS for use in US capital markets, provided that the following additional steps are taken:

• Limit the choices of GAAP available to foreign registrants to two: US GAAP or IAS.
• Require that foreign registrants comply fully with the same regulations that apply to US public companies, including reporting US or IAS GAAP financial statements for all interim periods.
• Actively support processes that will accelerate the development of a single set of global accounting standards that will be used in all securities markets.
• Ensure that US and foreign registrants are treated equally in all respects under federal securities laws, including the right of all registrants to follow IAS standards.
• Require that these changes be effected over a time frame of no greater than five years and do not 'grandfather' existing foreign registrants.