FSA's Comments on the Proposal for modernizing and simplifying the Listing Rules in the UK by the Financial Services Authority of United Kingdom

January 27, 2004
Financial Services Agency (FSA)

1. The Financial Services Agency (''FSA'') sent a comment letter on January 27, 2004 to the Financial Services Authority of United Kingdom (''UK FSA'') regarding the proposal for modernizing and simplifying the Listing Rules in the UK (''Proposal''), which was published on October 8, 2003.
2. Under the current UK Listing Rules, Japanese issuers with their securities listed on the London Stock Exchange (''LSE'') are allowed to use financial statements prepared in accordance with Japan GAAP. However, the UK FSA is requesting interested parties to send comments to the Proposal on the issue of whether non-EU overseas issuers with a primary listing or a secondary listing should be required to use IAS (International Accounting Standards) or US GAAP.3.
3. Japanese issuers have been conducting a lot of financial activities within the UK capital markets (''the City''). We believe it is important to maintain the open and global nature of the City. In addition, through the so-called ''Accounting Big Bang'' in the late 1990s and 2000s as a part of our ''Financial Big-Bang'', Japan GAAP has been rapidly developed and has become consistent with international accounting standards.
4. From this viewpoint, the FSA has decided to send the comment letter regarding the Proposal, and to request the UK FSA to continue to accept Japan GAAP.

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• (Reference) Comment letter to the UK FSA (PDF:26K)