May 5, 2008 Nancy M. Morris, Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-1090 FILE NO. S7-05-08; COMMISSION RELEASE NOS. 33-8900; 34-57409; FOREIGN ISSUER REPORTING ENHANCEMENTS Ladies and Gentlemen: This letter is submitted on behalf of the Organization for International Investment (“OFII”) and comments on a proposal by the Securities and Exchange Commission (the “Commission”) to make a number of changes to the Commission’s reporting rules for foreign private issuers. Although OFII endorses the Commission’s proposal to permit companies to test their “foreign private issuer” status once per year, it does not support the proposed acceleration of the deadline for annual reports filed by foreign private issuers. For many foreign private issuers, the proposed 90-day deadline (for accelerated filers and large accelerated filers) will be a significantly shorter deadline than the deadline imposed in their home country. Shortening the deadline will, therefore, create new burdens on foreign private issuers that could well serve as an impediment to attracting new foreign private issuers to the U.S. capital markets. About OFII OFII is an association representing the interests of over 150 U.S. subsidiaries of companies based abroad. Most of our members’ parent companies are publicly traded companies, some of which are foreign private issuers under Commission rules. These foreign private issuer parent companies file ...