REGULATORY AFFAIRS

Response to the U.S. SEC on Short-Term Borrowings Disclosures

November 29, 2010

The Institute of International Finance Senior Accounting Group submitted its response to the SEC on proposed short-term borrowings disclosures. The Senior Accounting Group generally supports the proposals’ objective to provide transparency about intra-period borrowing activity. However, the Group notes particular transition challenges for foreign private issuers (FPIs) and some operational difficulties in providing the proposed disclosures.