Mitsubishi Tokyo Finacial Group, Inc.October 16, 2003 Mr. Jonathan G. Katz, Secretary
RE: Proposed Foreign Bank Exemption from the Insider Lending
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.
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