Subject: File No. S7-27-08
From: Thomas N Tyson
Affiliation: Professor of Accounting, St. John Fisher College

January 21, 2009

As a professor who teaches both US GAAP and IFRS, I'm concerned about the problem of information overload for accounting students. It appears that both sets of GAAP will need to be imparted to students since there does not appear to be any roadmap for converting GAAP to IFRS for privately-held companies.

I'm not sure what the SEC can do about the matter, since private-company accounting falls outside their purview, but I can forsee the worst of all worlds occurring - the co-existence of two competing GAAPs and the need for accounting majors to master both