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U.S. Securities and Exchange Commission

Comments on Proposed Rule:
Revision of the Commission's Auditor Independence Requirements

[Release Nos. 33-7870; 34-42994; 35-27193; IC-24549; IA-1884; File No. S7-13-00]

Author: "James C. Anderson" at Internet Date: 09/09/2000 1:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents Regarding this issue, I put my trust in the expertise of the SEC which is commissioned to act in the interests of the American people. The potential for organizations which offer consulting and auditing services to affect reports to misrepresent fiscal results should be considered. The SEC is in the position to have knowledge of such conflicts and to cause such rulings as may be needed to prevent them. For this reason I encourage the Commissioner's to rule according to the evidence as it is known to them. Best regards, James C. Anderson Private Investor Tucson, AZ.

Author: "John Brown" at Internet Date: 09/09/2000 3:58 PM Normal TO: RULE-COMMENTS at 03SEC Subject: S7-13-00 ------------------------------- Message Contents Don't settle and seal the record. You stand between us (the investors) and the auditors. You look over their shoulder to see what is going on.. STAND FIRM. This is what goverment is for to make a level playing field. John Brown 711 N. Lakeview Dr. Rogers,Ar. 72756-3033

Author: Charles Campbell at Internet Date: 09/09/2000 3:48 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. -13 -00 ------------------------------- Message Contents Dear Sir: Regarding the separation of auditor duties from for the same company, I think that this would he be one more way of keeping the company reports free from wrong influence and give more credit to the report. Charles L. Campbell

Author: Jim Ferguson at Internet Date: 09/09/2000 1:45 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File NO. S7-13-00 ------------------------------- Message Contents Gentlemen: I am a small invester getting my investing feet wet with my company's 401K Plan and some selected on-line investing. After reading my latest Motley Fool email here's my take on the issue of separating auditing and consulting revenue streams in accounting firms.. It's a "no brainer". Any time in my business experience, when self interest and ethics collide...the opportunity for a decision favoring self-interest is real and all too probable. Why should you continue to allow even the hint of impropieity...given the risks to the investment community. The combined lobbying of the big accounting firms is substantial, but the SEC has an obligation to follow a course of simple common sense. Separate these two functions. Keep all us out here sleeping at night knowing that the financial summaries you require are accurate to a fault and any conclusions reached as the a firm's financial conditions are true and unbiased by other relationships. The SEC's job is to keep the honest people honest..maintain your reputation and stay the course. James A. Ferguson Plano, Texas.

Author: "Michael Gauthier" at Internet Date: 09/09/2000 5:40 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents To Whom it may concern, My name is Mike Gauthier, I am an individual investor in the stock market. I feel very strongly that the Auditors Independence rule is in the best interest of the public, and indirectly therefore publicly traded business. To allow any financial information to be undisclosed, altered, or "forgotten" due to the companies willingness to purchase consulting services is unacceptable. Thank you for your time. Sincerely Michael J. Gauthier A+, CCDA, CCNA, MCSE+I, Network+ mgauthier@dotnet.com Tel. (920) 477-5881 Fax (920) 477-3406

Author: "Guckes; Terry" at Internet Date: 09/09/2000 6:46 PM Normal Receipt Requested TO: RULE-COMMENTS at 03SEC Subject: Separation of Accounting and Consulting Services ------------------------------- Message Contents Gentlemen: I hope you make and enforce rules completely separating accounting and consulting services, so that a firm can choose to do one or the other but not both. Regards, Terry Guckes

Author: "George H Haas" at Internet Date: 09/09/2000 2:29 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Auditor independence ------------------------------- Message Contents I believe that one of the big differences between the US financial markets and other financial markets is that you can believe most of the financial data presented. There is the possibility that other business considerations by auditing firms could taint the unbiased reporting of the auditors. The audit divisions should at least be made to be in separate divisions of the company if not completely independent. A perceived conflict of interest is almost as bad as an actual conflict of interest. G.H.Haas

Author: at Internet Date: 09/09/2000 3:35 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents I encourage you to make it illegal for the "independent auditor" to have any part of its corporate entity doing business with the company being audited. Ron Homan

Author: "Don & Nancy" at Internet Date: 09/09/2000 2:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: S7-13-00 ------------------------------- Message Contents Auditing and consulting for a fee is a major conflict of interest. No public confidence should be given to any report of any firm that engages in this practice. Vivian D. Kilgore Jr.

Author: MARTIN_BEN at Internet Date: 09/09/2000 1:52 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents Gentlemen, As in individual investor I need up-to-date, accurate, complete and unbiased accounting reports from corporations and funds. Therefore I wholeheartedly support your pursuit of Auditor Independence. We all must be able to trust the audit reports and ensuring their independence will go a long way toward achieving that goal. Thank you, -- Ben Martin

Author: "J. Marty" at Internet Date: 09/09/2000 7:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents Gentlemen: As a Certified Public Accountant for 31 years and a very active auditor for the first six years, I would like the SEC to ardently pursue a rule prohibiting auditors from performing consulting engagements for audit clients. To the discredit of the accounting profession, it has moved from a profession to a marketing oriented "practice" or business and away from a "service profession". I personally believe that, in part, unrestrained litigation has caused large accounting firms to de-emphasize the practice of effective auditing techniques, relying instead on analytic review and enhancing income from audit services, consulting and tax services to "fill" their warchests to defend themselves against inevitable litigation and the resulting costs of defense and settle-ment. Other firms have been forced to follow in order compete with the "predator" bids of the larger firms with the staff to perform extensive consulting engagements. It is a sad state of affairs. If the practice of "cross-selling" of services were constrained, it may cause a renewed emphasis on effective auditing and, thereby, enhance the reliability of audited financial statements and protect the investing public. Considera-tion should also be given to limiting court awards to documented damages plus the cost of prosecution. If allowed to remain, punitive damages should be limited to a reasonable percentage of documented damages. Very truly yours, John L. Marty, CPA

Author: at Internet Date: 09/09/2000 4:24 PM Normal TO: RULE-COMMENTS at 03SEC CC: DONMYR@aol.com at Internet Subject: File No. S7-13-00 ------------------------------- Message Contents To Whom It May Concern: I am for the addition of restrictions on the provision of both Auditing and Systems Consulting Services for any corporation by the same company (i.e. one of the FAB FIVE). The potential for economic pressure on a corporation by an auditing comp;any not only puts the company at a possible disadvantage, but may also place the stockholders in a position of having no representation. Sincerely, Don Meyer

Author: "Clarence Munson Jr." at Internet Date: 09/09/2000 5:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: S7-13-00 ------------------------------- Message Contents As an investor I strongly support S-13-00 for obvious reasons. Clarence Munson P.O. Box 128 Oneonta,NY 13820

Author: at Internet Date: 09/09/2000 9:12 PM Normal TO: RULE-COMMENTS at 03SEC Subject: auditors and/vs consultants ------------------------------- Message Contents i wish to add my feelings and name to those who have already advises you that those who advise should not be the ones who do the audits. there is too great an opportunity for conflict of interest. sam ortenberg samort@aol.com

Author: Mike Di Paolo at Internet Date: 09/09/2000 5:49 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Audits ------------------------------- Message Contents Yes, I believe auditing firms can be swayed if they also do consulting. Businesses that do auditing should not also do consulting. This is necessary if the public is to have condidence in the audit. Mike Di Paolo 29 Cargill Drive Bella Vista, AR 72715 501 855 0998

Author: at Internet Date: 09/09/2000 11:09 AM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 & the SEC ------------------------------- Message Contents I want to thank the SEC for their past efforts at "leveling the playing field" for the smaller, individual investor. Your consistent efforts at making access to information available to all investors at the same time is a great policy. Consistent with that policy is making accountants adhere to a higher ethical standard, by separating them from the consulting function. I'm cynical enough about politics and large corporations, and really tired of "accounting irregularities" as being part of an investment strategy to find companies that have been devalued. While my thoughts are not well thought out on the subject, I would like to extend to the Commission my support and thanks for their efforts. Sincerely, Rick Percoco 16 Lark St., Greenwich, NY 12834


Author: at Internet Date: 09/09/2000 10:00 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents Dear Sir/Madam: I believe that the SEC should stringently and sharply investigate the practice of the large accounting firms' practice of not only providing auditing services to companies but also consulting services. At the present time, as well as the recent past, the increasing presence of auditing companies also providing consulting services present a conflict of interest that hurt investors and would be investors. A company providing both auditing and cosulting services may and sometimes do find it in their best interest to make recommendations and consultation advice that is adverse to the individual investor and the potential investor. I believe a puissant and serious investigation into this disturbing practice is carried out. Sincerely, Jeffrey Renye

Author: Jim Rice at Internet Date: 09/09/2000 5:40 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00 ------------------------------- Message Contents It is my opinion, as an individual investor, that it is important: 1. That the previous work done by the SEC for the selective disclosure issue is a great benefit to the individual investor 2. I likewise believe Auditor Independence should be as high a priority, even though it will be exteremely challenging to publicly demonstrate the extent of the problem. 3. It is my belief that there is also potential conflict of interest in these Auditor Consulting firms continuing to remain unbiased in representing consulting services advice to their customers when they are receiveing monetary benefit from equity ownership in high-tech software companies. (e.g. [Nasd:STCS] equity ownership by companies including AC, EDS, & SAIC) Thank you, Jim Rice

Author: at Internet Date: 09/09/2000 5:53 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Auditors vs. Consultants ------------------------------- Message Contents I would like to comment that I believe that firms should not be allowed to consult for firms that they audit. I believe that there is an inherent conflict of interest therein. Furthermore, I believe that this is one of those areas whereby the markets should want transparency and should want to set guidelines that the public could understand as "beyond reproach". As auditors are professionals, they should be held to the same standard as judges that from to time excuse themselves from cases, or attorneys that cite conflict of interest in doing the same. It would be one thing for a firm to perform these services for different clients. For an accounting firm to perform audit services and consulting services for the same firm, this is an apparent conflict of interest. I would think that an accounting firm would want to avoid even the appearance of a conflict of interest. Therefore, I cannot understand why a prominent firm would oppose this rule. Yours truly, Elliot M. Simon

Author: "Whitcomb" at Internet Date: 09/09/2000 3:56 PM Normal TO: RULE-COMMENTS at 03SEC Subject: "File No. S7-13-00" ------------------------------- Message Contents As an individual invester I depend on unbiased accounting procedures. I support your initiative to make company auditors independant. Thank you, Dennis Whitcomb 416 Roswell Rd apt NN4 Atlanta GA 30342