Letter From SEC Director of Corporation Finance and the SEC Chief Accountant to Cynthia M. Fornelli, Executive Director of the Center for Audit Quality, Concerning Release No. 33-9002, Interactive Data to Improve Financial Reporting — April 8, 2011

You have requested our views regarding the requirements for foreign private issuers that prepare their financial statements in accordance with International Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board (IASB) to submit to the Securities and Exchange Commission (Commission) and post on their corporate websites, if any, Interactive Data Files, as defined in Rule 11 of Regulation S-T.

As you note in your letter, Rule 405 of Regulation S-T requires issuers to prepare Interactive Data Files in accordance with the EDGAR filer manual, and Section 6.3.9 of Volume II of the EDGAR filer manual requires use of a taxonomy specified on the Commission's website. As you also note in your letter, the Commission has not specified on its website a taxonomy for use by foreign private issuers that prepare their financial statements in accordance with IFRS as issued by the IASB and it is not possible for such foreign private issuers to comply with Rule 405 until the Commission does so.

Accordingly, we are of the view that foreign private issuers that prepare their financial statements in accordance with IFRS as issued by the IASB are not required to submit to the Commission and post on their corporate websites, if any, Interactive Data Files until the Commission specifies on its website a taxonomy for use by such foreign private issuers in preparing their Interactive Data Files.

This position is based on the facts presented in your letter. Any different facts might require a different conclusion.

Sincerely,