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7 December 2007 Comment Letter

Comment Letter to the U.S. Securities and Exchange Commission in Response to the Concept Release on Allowing U.S. Issuers to Prepare Financial Statements in Accordance with IFRS

Kurt Schacht, JD, CFA and Gerald I White, CFA

File Number S7-20-07 Concept Release on Allowing U.S. Issuers to Prepare Financial Statements in Accordance With International Financial Reporting Standards.

File Number S7-20-07 Concept Release on Allowing U.S. Issuers to Prepare Financial Statements in Accordance With International Financial Reporting Standards.

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