Subject: File No. S7-04-00 Date: 05/10/2000 6:09 PM Jonathan G. Katz Secretary Securities and Exchange Commission Washington DC File No. S7-04-00 CONCEPT RELEASE ON IAS's I am writing to respond to certain of the questions you raised in your Concept document dated February 16, 2000 The majority of the questions revolve around International Accounting Standards and those issues are more appropriately dealt with by our sister organization, the IASC. Questions 15 and 16 raise issues involving auditors and I shall focus my remarks on those points. The Council of IFAC has been considering for some months proposals for the strengthening of IFAC and its abilities to monitor the compliance of our member bodies with its policies, and membership obligations (including ethical and auditing standards). The creation of a Forum of Firms is also being considered. Membership in this Forum would be restricted to firms undertaking transnational audits who agreed to abide by stringent obligations of membership. These obligations would include an independent, firm-wide, quality review program and the creation and support of a Public Oversight Board. In addition, steps are underway to introduce a program that would provide accreditation to individual accountants in a level of knowledge and competency in International Accounting and Auditing Standards. Approval for development of all of these proposals is to be considered by the IFAC Council at its meeting scheduled for May 22-23 in Edinburgh. If, as we expect and hope, the proposals are accepted, work will proceed over the next 6-12 months to flesh out these concepts and introduce these programs. Development will certainly consider work done in many countries, including the pronouncements of the AICPA SEC Practice Section. We will, of course, keep you informed as work progresses. James M Sylph Technical Director ===================================================================== James M. Sylph FCA International Federation of Accountants (IFAC) Secretariat Technical Director 535 Fifth Avenue, 26th Floor New York, NY 10017, USA