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Staff Comments on Annual Reports Containing Financial Statements Prepared for the First Time on the Basis of International Financial Reporting Standards

In 2006, the SEC staff reviewed the annual reports of more than 100 foreign private issuers containing financial statements prepared for the first time on the basis of International Financial Reporting Standards, commonly referred to as IFRS.

Review and comment process

Our reviews of these reports are part of our normal review process in that they involve an exchange of comments and responses with companies as well as amendments to their filings where appropriate. In our normal review and comment process, we may raise different issues with different companies depending upon the facts and circumstances of each company and its disclosure. This can create a difference in the nature of our comments and the length of the review process. Consistent with our normal practice, in some comment letters, we asked companies to provide us with additional information, and in other comment letters, we asked companies to revise their financial statement presentation or enhance disclosure in future filings. In some comment letters, we asked companies to amend their filings.

We followed the same policies in raising comments on IFRS financial statements as we do in raising comments on U.S. GAAP financial statements. In all cases, when issuing comments on a company's disclosure, we seek improvements in disclosure that will enhance an investor's understanding of the company's financial statements. As part of our normal review process, we often ask a company to explain how it applied a particular accounting principle to a given transaction or set of transactions so that we, and investors, may better understand the presentation. Our doing so does not mean that we have concluded that a company's disclosure or financial statement presentation is incorrect or that a company has inappropriately applied an accounting principle.

Our review of these reports is part of the Division of Corporation Finance's regular review program. Section 408 of the Sarbanes-Oxley Act of 2002 directs the SEC to undertake a regular and systematic review of companies reporting under section 13(a) of the Securities Exchange Act of 1934 no less frequently than once every three years. The Division reviews many companies more frequently and reviews some number of companies every year. On occasion, and as appropriate, the Division consults with other regulators.

Staff observations in our reviews of IFRS financial statements

We present our general observations resulting from our review of financial statements prepared for the first time on the basis of International Financial Reporting Standards on the SEC website at http://www.sec.gov/divisions/corpfin/ifrs_staffobservations.htm.

Staff comments and company responses to those comments

From the items listed below, you can access the following information from the SEC's EDGAR system:

the company's filings on the EDGAR system;
the Form 20-F containing the financial statements prepared for the first time on the basis of International Financial Reporting Standards;
the correspondence relating to the staff's review of that Form 20-F.

We will continue to update this information as we complete our reviews and post correspondence to the EDGAR system.

The filings of all reporting companies, including those filed by companies presenting their financial statements in accordance with U.S. GAAP, and correspondence relating to staff review of those filings is available on the SEC website at http://www.sec.gov/edgar/searchedgar/webusers.htm.

ABBEY NATIONAL PLC (CIK: 1087711)
20-F, Filing date: 2006-06-26