In summary, while the FAF and the FASB continue to support strongly the ultimate goal of a single set of high-quality global accounting standards as part of a global financial reporting system, in our view, additional study is needed to better identify, understand, and evaluate the strengths, weaknesses, costs, and benefits of possible approaches the U.S. should take in moving toward that goal.

Thus, we reiterate our support for a study that would have as its focus a thorough analysis of the issues identified by the SEC in the Roadmap as well as the issues outlined in this letter. Ideally, the study would establish criteria to use in evaluating alternative paths toward the desired end, consistent with a framework such as is embodied in the recent GAO report on financial regulation.

We note that given the complexity and magnitude of the issues involved, the study may not yield clear answers and that any decision about the path forward will involve tradeoffs. However, the point of the study is to reduce uncertainty as much as possible so as to ensure that the ultimate decision represents an effective path forward to achieving high-quality, internationally comparable financial information that capital providers find useful for decision making in global capital markets.

Finally, in this increasingly interconnected financial world, all investors, regardless of country, benefit from high-quality financial information. Thus, as the SEC thoughtfully considers the issues raised by the Roadmap and by the public debate generated through the comment process, we remain committed to continuing to work closely with the IASB to improve both U.S. GAAP and IFRS and to eliminate differences between them. We believe these joint efforts will improve the quality of the standards and the comparability of financial information globally and will advance the efforts toward a single set of high-quality global accounting standards.