Comments on Proposed Rule:
Auditor Independence Requirements
Release Nos. 33-7870; 34-42994; 35-27193; IC-24549; IA-1884; File No. S7-13-00
Author: "Kyrna Ball" at Internet
Date: 09/08/2000 9:55 PM
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TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-13-00; 1 Vote of Approval
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Dear SEC Rulemaking board...
First, thank you for the monumental assistance in obtaining the "Ban against
Selective Disclosure." As an individual investor, I consider this a major
accomplish by the SEC for individual investors across the country.
Currently, John Bogle, founder of the Vanguard Group, has recently testified
as to the decline of in the "value" of an independent audit.
'SEC Chairman Arthur Levitt gave the details to the reasoning behind the
rule in a spring speech. There's quite a bit to chew on, but for individual
investors the matter is pretty simple:
Auditors might be skimping on the their audit responsibilities where there
are big dollars at stake on consulting fees. Auditors often offer clients
consulting services, yet these are the same companies they're supposed to be
rigorously auditing.
And since 1993, auditing revenues have grown a feeble 9%
annually, while consulting and similar services have grown at
the far brisker rate of 27%. ' ...
"Are Auditors Independent" Bill Barker, Motley Fool, (9-8-00)
This is an issue of paramount importance to the individual investor, and
should be pursued with the utmost enthusiasm by the SEC.
I request that the SEC vote, (rule) in favor of a "Separation of
Responsibilities between Independent Auditing and Consulting". The practice
of offering clients consulting services, in addition to auditing the same
company should not be permissable.
If a separation of responsibilities between auditing and consulting services
is not a possible, viable solution, then the auditor must be held
accountable for questionable accounting practices and reporting procedures.
Sincerely,
Kyrna A. Ball
Kaball@uswest.net
Author: "Charles E. Bassett" at Internet
Date: 09/08/2000 10:32 PM
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TO: RULE-COMMENTS at 03SEC
Subject: Regarding File No S7-13-00
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Just a note to let you know that we support your efforts to cleanse the
Audit industry. The conflict of interest to the public from mixing
audit services with consulting services must be remedied.
Author: Craig M Boyer at Internet
Date: 09/08/2000 9:22 PM
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I would just like to voice my opinion as a concerned citizen and a
potential accounting career professional about the conflicts of interest
present when accounting companies perform both audit and consulting
services. Accounting companies already face the dilemma of pleasing
their clients to retain their services versus providing full disclosure
of negative aspects of any given client. Consulting has added to this
conflict of interest because now accouting companies have even more
incentive to see good performance from their clients rather than being
independent analysts of companies' financial positions. Please give this
issue serious consideration since it has direct implications for the
financial well-being of all Americans.
Sincerely,
Craig Boyer
craigboyer@juno.com
Author: Kerry at Internet
Date: 09/08/2000 11:56 PM
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I find it difficult to imagine that an accounting firm can be a good
independent auditor and also still have that same client as a consulting
client. It seems to me that the two are to a great degree mutually
exclusive. Which job has the highest earning for the accounting firm?
That is going to be the side of the bread that is buttered! It would be
better if the public company had to hire a separate independent auditing
firm from the firm that consults them on accounting practices and
procedures.
Kerry Brasswel
Tax Accountant (CTP)
Author: "Charles R. Busfield" at Internet
Date: 09/08/2000 8:24 PM
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I would simply like to advise the SEC that I am concerned about what
would seem to me to be the clear and troubling potential conflict of
interest inherent when an auditing firm offers consulting services to a
company that it is supposed to be rigorously auditing.
As an independent investor I strongly support what I understand to be the
SEC's position that auditing and consulting services should be kept
separate to prevent conflict of interest.
Regards, Charles R. Busfield.
Author: Eric Casper at Internet
Date: 09/08/2000 10:05 PM
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Subject: File No. S7-13-00"
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As a tax attorney who regularly works with accounting firms, I
strongly support the proposal for independence between auditing and
consulting. I am sure that the auditing function gets compromised all
the time because of this. The pressures are strong enough when you are
doing a big audit for a large client to keep the client, they clearly
are much more so when the audit function is not a significant part of
the income from that client. Eric Casper: ecasper@walkersilver.com
Author: at Internet
Date: 09/08/2000 11:00 PM
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As an investor I read that auditors often offer clients consulting services,
yet these are the same companies they're supposed to be rigorously auditing.
And since 1993, auditing revenues have grown a feeble 9% annually, while
consulting and similar services have grown at the far brisker rate of 27%.
The conflicting interest is obviously growing. I believe the SEC should stop
this practice to ensure the financial reports presented to investors are
valid.
Gordon Collinson.
1617 La Verde Dr.
San Marcos Ca 92069
Author: "Jim Davidson" at Internet
Date: 09/08/2000 11:30 PM
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Auditors should only be authorized to offer audit services. We, investors,
should not have to look a some special statement that states there is no
conflict of interest. If it is eliminated no conflict of interest should occur.
Jim Davidson
Author: Daniel Dvorak at Internet
Date: 09/08/2000 4:20 PM
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As an individual investor I strongly support the SEC's initiative on
Auditor Independence. It defies common sense to think that an auditor can
be rigorously objective knowing that an unflattering audit result will hurt
more lucrative business of his/her own company.
Daniel Dvorak
Glendale, CA
--
Daniel Dvorak, M/S 301-270 phone: 818-393-1986
Jet Propulsion Laboratory fax: 818-393-6558
4800 Oak Grove Drive email: dldvorak@pop.jpl.nasa.gov
Pasadena, CA 91109-8099 http://eis.jpl.nasa.gov/~dldvorak
DISCLAIMER: All personal and professional opinions presented herein are
my own and do not, in any way, represent the opinion or policy of JPL.
Author: "Ron Ewing" at Internet
Date: 09/08/2000 9:09 PM
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Sirs:
I am a concerned investor, and a financial analyst, and would like to
comment on the proposed regulations involving auditor independence. It is my
strong feeling that the independence of auditors must be safeguarded. I
believe that the Commission should adopt regulations that will prohibit an
audit firm from providing non-audit consulting services to their audit
clients.
It is very clear to me that a potential conflict of interest arises when an
auditing firm pursues lucrative consulting fees with an existing audit
client. The auditing firms will protest that no proof exists that any audits
were intentionally lax for this reason, but proof of such an occurrence is
unlikely to ever be revealed. For one thing, such a proof would almost
require demonstration of intent and motive; i.e., what was in the mind of
the auditors, vs. what actions were/were not taken by the auditors. For
another thing, if such proof existed, it is likely that it would be either
destroyed or that through legal settlement, the records would be kept
confidential.
I would propose that audit firms need not forego consulting altogether - they
could continue both auditing and consulting, if they chose. They just
couldn't audit the same client that they provide consulting services for.
This would reduce the downside for auditing firms, because they could still
get consulting fees. As a result, the synergies they claim to exist (keeping
their talented people exposed to the state of the art in their profession)
would continue. Their revenues should not be overly harmed (they can still
consult), but their expenses will probably increase somewhat as they bear the
costs of marketing to a wider audience to retain the same volume of business.
At the end of the day, the question is this: Who is the audit client? The
corporation that needs the audit? Or the investing public? The answer, of
course, is the investing public. The corporation, left to its own devices,
would just as soon avoid the expense and inconvenience of an audit.
Corporations suffer the intrusion of an audit in order to comply with SEC
regulations for the privilege of being able to go to the public to raise
capital in the markets.
I believe that the commission has an obligation to come down on the side of
the investing public on this issue. Enacting regulations that will help to
ensure auditor independence is the right thing to do. The markets work as
well as they do at least partly because of our transparency - one piece of
which is the required audited financial disclosures. If we're going to go to
the trouble of auditing the statements, we might as well do it right.
Thank you for your attention and consideration.
Ron Ewing
Author: "Maurice Fricke" at Internet
Date: 09/08/2000 7:03 PM
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Subject: File No S7-13-00
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You know objectivity is lost and we (ordinary citizens) know objectivity is
lost. The only ones fighting your proposed rules are the companys corrupting
the system. Give them a spanking and clean up the playing field.
M Fricke.
Author: at Internet
Date: 09/08/2000 10:11 PM
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Subject: File No. S7-13-00
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I am an individual investor and am appalled to learn of the widespread
practice of auditing firms providing consulting services to clients that they
are supposed to be auditing with rigor. It does not take genius to recognize
that this is clear cut conflict of interest. Please take appropriate action
to stop this deplorable activity.
Author: at Internet
Date: 09/08/2000 5:11 PM
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TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-13-00
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I am a small, private investor and the Auditor Independence rules that
you are considering are good and I support them.
1. It's important to avoid the appearance of a conflict of interest, as
well as an actual separation of duties. That's a key component of any
internal control system and auditors and accountants should know this.
2. This type of regulation, that ensures accurate information, is vital
to the success of the US economy. As a consumer, I need to be able to
(sort of) trust some information. One of the reasons our economy is
vibrant is that businesses are required to follow some laws. It can't
all be laissez-faire or it might as well be might makes right!
Thanks for your good work! Cynthia Guest
Author: "Don Hoeger" at Internet
Date: 09/08/2000 9:25 PM
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Subject: File No. S7-13-00
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To whom it may concern,
I would like to voice my concern over the issue about the conflict of
interest of auditors offering both audit services and consulting services.
I am concerned that the growth in consulting services, which has far
outweighed the growth in auditing revenues, could create a problem with the
thoroughness, and completeness of an audit when this conflict exists. I
appreciate you looking into this matter and protecting the interests of the
individual investor.
Thank you,
Don Hoeger
Author: "Bruce Hull" at Internet
Date: 09/08/2000 6:51 PM
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CC: "Bruce \(yahoo\) Hull" at Internet
Subject: File No. S7-13-00
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To Whom:
I appreciate your attempt to enforce ethical standards in what must be a sticky
situation resulting from sealed court documents (it is rumored) that prevent you
from telling the whole story behind your rigorous pursuit to try and limit the
self same company from performing the audit function of a fiduciary trustee,
while at the same time selling lucrative consulting services valued at many
times the revenue of the audit fees, to the company being audited. Common sense
tells me that this is an obvious conflict of interest for any company engaged is
such practices.
I have been personally affected by this issue (in my opinion) several years ago.
I was and still am a stockholder in Informix Corp. which you may remember had a
horrendous issue regarding restated earnings. I felt that the auditors in that
situation should have been held accountable and someone should probably have
gone to jail. I would have also liked to see Phil White do some hard time in
that situation to make amends for his involvement. What a coincidence that Phil
White also sits on the board of Microstrategy during the remarkably similar
restatement of earnings that has cost stockholds over a BILLION dollars to date.
Go get 'em! Make 'em do it right, or make 'em pay!
Bruce Hull
Individual Investor
Author: kate johnston at Internet
Date: 09/08/2000 11:47 PM
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TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-13-00
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As an independent investor, I would welcome ANY efforts on your part to
ensure that the "independent auditors" of a publically traded company
had NO, absolutely NO, consulting contracts, alliances, or other
affiliations with the company they were auditing.
Motley Fool reports that auditing makes 9% profit while accounting
consulting earns over 25% profit.
Perhaps if the two functions were forced to separate, we could create a
more reliableAUDITING profession that could command higher rates based
on their independence and integrity.
As an informed independent investor, I would assign greater credibility
to those companies that chose to pay for "quality" independent audits.
All of this assumes that the SEC will put into place a means to
encourage companies to list, in their annual reports, those accounting
companies that they have "consulting" contracts with or other
"alliances" or "affiliations."
Thanks!
Kate Johnston
4701 Mc Campbell Drive
Knoxville, TN 37918
--
Kate
Author: Dolores Kenyon at Internet
Date: 09/08/2000 8:23 PM
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This email is to let you know I appreciate the work the SEC is doing on
the selective disclosure issue on behalf of the individual investor.
Even though the extent of the problem can not be publicly
demonstrated, I know the Commission has good reasons for doing this
as well as making it a high priority. Keep up the good work!
Dolores Kenyon
dmkenyon@swbell.net
Author: "Don Kutch" at Internet
Date: 09/08/2000 9:51 PM
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Subject: File No. S7-13-00
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Even the "appearance of impropriety" should be avoided in regard to firms
which audit public companies. That means that they should NOT serve as both
consultant and auditor.
Author: "Elaine Langer" at Internet
Date: 09/08/2000 9:10 PM
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Subject: File #S7-13-00
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To Whom It May Concern:
I am sending this e-mail to express my support for the SEC's proposed
investigation and possible regulation of how truly independent "Independent
Auditors" can be, if these auditors also perform lucrative, non-audit services
for the same companies they are auditing. Although there may be no "hard"
proof at this point, or "hard" proof may be difficult to obtain, common sense
leads me to believe that such regulation is necessary, even if the audit is
affected "unintentionally". It seems to me that it would be very difficult to
be scrupulously objective when large fees might be affected by the outcome of an
audit.
Sincerely,
Elaine Langer
1128 N. 27th St.
Allentown, PA 18104
eclanger@enter.net
Author: Wot Dabny at Internet
Date: 09/08/2000 11:31 PM
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I am writing in regard to the SEC's new look at
Auditor Independence. I know it is not a popular issue
with the auditing profession, and I can appreciate
that no one likes to have their sincerity or integrity
questioned.
However, the simple fact remains that free market
systems work best when incentives are aligned in such
a way that all involved are in the same boat.
Establishing true auditor independence is therefore an
important step in the right direction.
Imagine how different the investing world would be if
mutual fund managers were paid based on how much money
they made for their clients.
Wherever incentives are poorly aligned with the best
interests of all involved, corruption -- or at the
very least, considerable inefficiencies -- creep in.
Auditor independence stands to benefit everyone in the
long run, and nearly everyone immediately. Those whose
incomes might be hurt by it, well, I don't have any
kind words for them anyway, as they benefit at the
expense of the capital markets.
Sincerely,
David Langford
Author: "Frank A. Love" at Internet
Date: 09/08/2000 8:21 PM
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I have just read of the possibility that auditors or their employers may, in
addtion to being paid for an actual audit also collect "consulting fees" which
are in fact far in excess of the proceeds from the audit itself.
I have further read that you are considering a ruling which would regulate or
ban such fees and that the primary feedback you are receiving on this proposed
rule is from the accountants themselves.
I am not an accountant, I'm just someone who invests moner based on the results
of those audits. As an investor who stands to lose money if the quality of
audits is affected by ths practice, I would urge you to remove even the
appearance that any undue influence might be involved in the auditing process.
In my opinion, such a practice could easily lead to such apprehensions, so I
urge you to implement any rules or regulations you see fit to eliminate this
pratice as soon as possible.
Yours,
Frank A. Love
1217 Chester St.
Birmingham, AL 35226
Author: "Bob & Clover Matter" at Internet
Date: 09/08/2000 6:29 PM
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I'm on the SEC's side on Auditor Independence. I think the auditors need to be
audited!
Bob Matter
4568 Rd. G.6 NE
Moses Lake, WA 98837
bjmatter@atnet.net
Author: Harihara Moorthy at Internet
Date: 09/08/2000 7:04 PM
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I fully support SEC's efforts to ensure
"Auditor Independence" even if it is
difficult to positively demonstrate the
existence of a problem. The mere possibility
that auditors may have a conflict of interest
justifies the investigation.
Thanks, H. Moorthy
Author: Larry at Internet
Date: 09/08/2000 8:26 PM
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I feel strongly:
the profession of accounting has turned
into the business of consulting and cross-selling. It has
potentially very adverse consequences to the public
interest and has now become a business of
marketing, and the public interest, has
not been served thereby. So I feel strongly about the
divorce of outside services from the audit services."
Lawrence Morton
2816 Kensington Dr
Kalamazoo, MI 49008
Author: "Nelson; Donna" at Internet
Date: 09/08/2000 4:30 PM
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To whom it may concern:
I believe it is essential to maintain independent audits of publicly traded
companies: that is, audits unencumbered by any other relationship with the
entity being audited. As an individual investor, I do not have the ability
to monitor the financial status of my investments personally, and rely on
the unbiased opinion of the auditors contracted to perform an audit on
behalf of the stockholders.
Please pursue the establishment of this rule.
Donna G. Nelson
ESIS Architecture and Strategy
Intel Corporation
* voice: (916) 356-6858
* fax: (916) 356-7722
* mailstop: FM3-146
* email: mailto:donna.nelson@intel.com
Author: "Laurel Parshall" at Internet
Date: 09/08/2000 5:39 PM
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I just wanted to put in my backing put a stop on this particular issue of
auditors as consultors/advisors. It sounds like conflict of interest is in play
as far as I'm concerned. Putting temptation in anyone's path on a regular basis
can almost guarantee that a percentage will fall.
Thanks for listening.
Sincerely,
Laurel Parshall
Author: "Rodger Petersen" at Internet
Date: 09/08/2000 6:17 PM
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I am a fairly typical small investor. I try to be a prudent investor but
have a great deal of difficulty believing the "audited" statements.
I believe the consulting and accounting pracices have to be divorced to
provide a climate in which auitors will have less business pressure put on
them to "hit" prescribed figures. Twenty-five years in the financial
industry assures me that outcomes are at times dictated.
Thank you
R.E. Petersen
Author: "Mark Pfau" at Internet
Date: 09/08/2000 9:19 PM
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I fully support the complete separation of audit services and consulting
management services by publicly traded companies, on all exchanges. The
conflict of interest problem is obvious, if not documented.
Mark I. Pfau
Individual Investor
Author: at Internet
Date: 09/08/2000 7:54 PM
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Dear SEC---- I am against the concept that the Financial Auditor Firms can
provide independent Financial/Business services to the same clients. There
is an inherant conflict of interest in remaining "independent". Please
prohibit these firms from providing both services to the same business
entitities. They must pick one service or the other.
I am a Professional Engineer and was a 10% owner of a national $500M
professional fee service company. What was supposed to be a profession to the
public, turned into a business for the benefit of the company, and the public
was not as well served due to self interest.
Thanks,
Doug Prescott
2505 Silver Cloud Drive
Park City, Utah 84060-7040
tele 435-649-7405
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Author: at Internet
Date: 09/08/2000 7:51 PM
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Stop the game playing. Anyone who has worked in healthcare fiscal affairs has
watched Big 8 auditors leverage in their consulting operations, then
virtually run the business operation, while auditing the operation. Needless
to say each creates the need to continue the use of the other, at the expense
of the public, with impossible to contest audits to prove the need.
Author: at Internet
Date: 09/08/2000 7:54 PM
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Dear Sirs:
As a private citizen and investor, I strongly feel that there must be
separation between the auditing firm and the consulting firm. They must be
separate and independent in order not to be compromised. The present practice
of an auditing firm doing an audit on a company and at the same time provide
in high priced consulting is not keeping the fox out of the hen house.
Sincerely,
Edward M. Sawtelle
10 South Derby Ave.
Ventnor, NJ 08406
Author: David Schaefer at Internet
Date: 09/08/2000 5:07 PM
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I fully agree with the SEC position that auditing and consulting should be
done by two seperate entities when dealing with a company, especially a
publicly held company. There are no room for errors in financial statements
considering the wild swings in stock prices at the mere implications of any
impropiraty.
David Schaefer
Scotts Valley, CA
Author: "Richard Seaman" at Internet
Date: 09/08/2000 7:57 PM
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I wish to express my support for making auditing firms being restricted from
other consulting services with those that they audit. I have seen the
results of the audits prepared by firms performing consulting services for
the audited firm. The recommendations made by auditors are sometimes
impacted due to the consulting work.
Author: "Jonathan Seidman" at Internet
Date: 09/08/2000 6:58 PM
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You guys should definitely go after these auditors. How are investors suppose
to judge the worth of a company's stock if they aren't being truthful in their
accounting. If there are companies out there doing what MicroStrategy did, we
need to know about it. Go get'em.
Author: "Bob Sharkey" at Internet
Date: 09/08/2000 6:50 PM
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I believe that I have been harmed by inadequate, and what seemed like very
poor auditing of company records. Too often the auditors come in to check what
the company has previously set out for them. That is not independent. For the
auditing firm to correctly do its job they should be able to look at any records
they request. When they have a contract to do consulting work also, they seem
to ignore checking things that the company does not want them to check. It
seems like you pat my back and I'll pat yours. It won't be easy to separate the
branches of an accounting firm, but it would be necessary for each to be
independent of the other.
Thank you,
Robert L. Sharkey
2764 Old Military Rd.
Mountain Home, AR 72653-6340
(870) 425-0171
Author: MARVIN SLATKIN at Internet
Date: 09/08/2000 11:51 PM
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To whom it may concern,
I am pleased to have an opportunity to voice an opinion on this matter of
potential conflict of interest. I will be brief.
It was always difficult for me to believe a business would suffer an
auditing firm that would not put questionable practices in the very best
light. I would expect the business to require the auditor to turn a sow's
ear into a silk purseS if one was found, of course.
This situation hasn't served the investor, particularly the small ones (me,)
as the many recent financial fiascos have demonstrated.
To expect these very firms to add consulting, a service which implies an
aggressively partisan relationship, and then turn around and perform a
rigorous and thorough audit (that would uncover sloppiness, dishonesty,
fraud, nepotism and whatever else) boggles the mind!
Why don't we have the district attorney be the judge too? Or the builder
inspect his own project?
Why shouldn't independent auditing firms be paid by a public agency and
assigned to companies. There would still be opportunities for dishonesty,
but they would be fewer and easier to prove. The auditors could be held
responsible for the professionalism of their audits. No sealed settlements.
The consultants should have their own businesses.
If the SEC doesn't straighten this situation out, greed will kill the goose
that has been laying the golden eggs. When enough megafailures occur who
will be left to invest in businesses with unbelievable balance sheets?
Yours truly
Marvin Slatkin
Author: "Paul F. Stelling" at Internet
Date: 09/08/2000 5:19 PM
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Dear Sirs/Madams:
As a former employee of a large accounting and consulting firm
(and current investor), I felt the need to comment on the
"Auditor Independence" rules being considered that would prevent
a firm from providing consulting services to a company for which
it conducted the "independent audit".
I am very concerned about the independence of an auditor that also
had large consulting contracts with an audit client. The potential
for self-interest to dominate honest independent audit assessments
is very large. While I cannot point to any cases of first-hand
knowledge where the outcome of an audit was compromised when
consulting contracts were in place, the officers of the accounting/consulting
firm involved would be derelict in their responsibilities to their own
firm if they did not discuss critical matters with each other. This could
lead to extreme influence being brought to bear to delay reports or
even hide/ignore information if it could adversely affect the consulting
contracts. I know that the accounting/consulting firms view audit and
consulting services as a foot in the door for obtaining contracts to
provide the other services as well, but I believe that this is one situation
where the public's need for true independence, and the associated
faith and confidence in the system, outweighs the cost of lost business
opportunities to the accounting/consulting firms. (I don't, however,
have the same concerns about a firm providing either both tax and
audit services or both tax and consulting services to the same client.
There, the benefits of cost savings due to the reduction of duplication
of effort, and the scale of the contracts involved make the risk far
lower. Also, the penalties associated with fraudulent tax preparation
serve as a significant incentive to maintain honest and independent
operations that doe not exist with otherwise unregulated consulting
services.
Thank you for taking my ideas and opinions into account.
-Paul F. Stelling
--
_________________________________________________________________
Paul F. Stelling O- Tel: (310) 336-7574
The Aerospace Corporation Fax: (310) 336-1812
P.O. Box 92957 - M4/960 Home: (310) 378-6781
Los Angeles, CA 90009-2957
U.S.A.
Author: David Thompson at Internet
Date: 09/08/2000 9:46 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-13-00
------------------------------- Message Contents
Dear Sirs,
RE: File No. S7-13-00
Please consider this email my whole-hearted endorsement of the SEC's efforts
to achieve Auditor Independence. I am a individual investor and I greatly
appreciate the SEC's rules & regulations that cultivate fairness for the the
private citizen in this complex and unforgiving world of investing.
Thank you for your continued efforts on our behalf.
David Thompson
1451 Beach Park Blvd #216
Foster City, CA 94404
Author: "R Trew" at Internet
Date: 09/08/2000 9:47 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: "File No. S7-13-00"
------------------------------- Message Contents
I am an individual investor and I think allowing audit firms
to act as consultants and advisors to public owned companies
is like having a fox guard the henhouse. Common sense says
there is a conflict of interest and it should NOT BE
ALLOWED.
Thanks,
Ralph Trew
Author: "Maryrose Turner" at Internet
Date: 09/08/2000 9:16 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-13-00
------------------------------- Message Contents
Dear Sir/Madam,
I have just read about the SEC investigating auditor independence. As an
individual investor, I would favor restrictions on accounting firms that audit
and then provide consulting services. It would appear that small guys like
myself have a lot to lose by insider information generated by these deals.
Thank you for listening to me, and millions of other individuals.
Sincerely,
Maryrose Turner
3609 Castellaine Drive
Charlotte, NC 28226
Author: "Janet H. Williams" at Internet
Date: 09/08/2000 9:27 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: File # S7-13-00
------------------------------- Message Contents
Separate the audit from the consultant. Then there is no possible way to
perceive impropriety.
Additionally, auditor could then increase their charges.
"JW"
"Victorious warriors win first and then go to war; while defeated warriors go to
war first and then seek to win." Sun Tzu
Author: dick welsh at Internet
Date: 09/08/2000 6:31 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: File# S7-13-00
------------------------------- Message Contents
Dear SEC,
I am heartily in favor of possible proposed regulations to make sure
that auditing companies, whose clients are exchange traded companies,
are not allowed to have consulting contracts with the same companies
they are auditing. The opportunites for improprieties that compromise
the audits, and therefore harm investors who rely on those audits for
supposedly unbiased information, are obvious and there should be safe
guards against such possibilities.
Sincerely,
Helen Welsh
Author: "Mark White" at Internet
Date: 09/08/2000 9:57 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: S7-13-00
------------------------------- Message Contents
I am all for having separation of auditing and accounting services being
provided.
Author: "taichiplayer" at Internet
Date: 09/08/2000 7:32 PM
Normal
TO: RULE-COMMENTS at 03SEC
Subject: file no. s7-13-00
------------------------------- Message Contents
As an individual investor I must take the financial statements of companies
at face value, and I am distressed to hear that the auditing firm may have
consulting contracts with the same companies. This seems to be conflict of
interest, or at the least it causes doubt about the integrity of the audits.
I urge you to prohibit this practice being done by auditing firms. Thank you
for the recent full disclosure rule change.
Richard Woodburn
http://www.sec.gov/rules/0908b01s.htm
