September 22, 2000
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
Re: File No. S7-13-00
Proposed Rule Amendments Regarding Auditor Independence
Dear Mr. Katz:
I am writing as legal counsel on behalf of the North Carolina Board of CPA Examiners (the "Board"). At its meeting on September 11, 2000, the Board discussed the Commission's proposed rule amendments regarding auditor independence requirements (herein, the "Proposed Rule").
Based on that discussion, the Board respectfully requests that the comment period for the Proposed Rule be extended beyond the currently scheduled September 25 deadline. This reflects the Board members' respect for the complexities of the issues involved and their desire to give the matter further serious thought before making any substantive comments.
In particular, we note that the Proposed Rule was discussed at the recent annual meeting of the National Association of State Boards of Accountancy (NASBA). The members of the North Carolina Board, having benefited from attendance at the NASBA meeting and direct participation in this discussion of the Proposed Rule. The Board, however, would not be able to consider a formal response until the next meeting (October 9). We assume that some other state accountancy boards likewise may find it useful to have a meaningful opportunity to meet and consider comment following return of their members from the NASBA meeting.
Should you have questions or desire further information about this request, please telephone me at (919) 755-0505. We appreciate consideration of this request by the Commission and its staff.
Very truly yours,
Noel L. Allen