Mitsubishi Tokyo Finacial Group, Inc.

October 16, 2003

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

RE: Proposed Foreign Bank Exemption from the Insider Lending
Prohibitions of Exchange Act Section 13(k) - (File No. S7-15-03)

Dear Mr. Katz:

We are pleased to respond to the Commission's request for comments on proposed Rule 13k-1 under the Securities Exchange Act of 1934, as amended.

We share the concerns expressed in the comment letter of Sullivan & Cromwell LLP that is being submitted today and we support the alternative proposals and additional revisions suggested in the comment letter of Sullivan & Cromwell LLP.

We would like to request that the Commission give due consideration to the views expressed in the letter.

Very truly yours,

Tatsunori Imagawa
Senior Managing Director
Mitsubishi Tokyo Finacial Group, Inc.