December 21, 2004
Financial Services Agency, Japan

FSA's Comments on the draft ''Concept Paper on Equivalence of Certain Third Country GAAP and on Description of Certain Third Countries Mechanisms of Enforcement of Financial Information'' by the Committee of European Securities Regulators

1. The Financial Services Agency (FSA) sent a comments letter on December 21, 2004, regarding the draft ''Concept Paper on Equivalence of Certain Third Country GAAP and on Description of Certain Third Countries'', which was published on October 21, 2004, by the Committee of European Securities Regulators (CESR).

2. In the European Union, third country issuers will be required, from around 2007, to prepare and present financial statements on the basis of IAS/IFRS or the third country's national accounting standards if these standards are equivalent to IAS/IFRS. For this reason, the CESR will give technical advice on the matter of equivalence between certain third country GAAP (i.e., Japanese GAAP, US GAAP and Canadian GAAP) and IAS/IFRS to the European Commission by June 30, 2005, as a part of the process for assessing equivalence of third country GAAP.

   As a first step in preparing its technical advice, the CESR published the draft ''Concept Paper on Equivalence of Certain Third Country GAAP and on Description of Certain Third Countries Mechanisms of Enforcement of Financial Information'' on October 21, 2004, which is open for comments from interested parties until December 22, 2004.

3. The FSA sent a comments letter regarding the aforementioned draft paper to request the following to the CESR as well as to express its views on the technical issues, in close cooperation with the relevant Japanese parties:

   • to make further efforts to ensure a fair, unbiased and transparent process for assessing equivalence of third country GAAP

   • to give priority to the promotion of the global and open nature of the EU capital markets and ensuring investment opportunities for investors in the EU capital markets as well as the protection of investors

   This comments letter is part of our efforts for the recognition of the equivalence of Japanese GAAP with IAS/IFRS, following our participation in the open hearing by the CESR on November 23, 2004.