COMMENTS

REGARDING

UNITED STATES OF AMERICA

SECURITIES AND EXCHANGE COMMISSION

PROPOSED RULE:

REVISION OF THE COMMISSIONíS INDEPENDENCE

REQUIREMENT

FILE NO. S7-13-00

BY

BRUCE COMMITTE
DOCTOR OF PHILOSOPHY
CERTIFIED PUBLIC ACCOUNTANT
ATTORNEY AT LAW
17 SOUTH PALAFOX PLACE, SUITE 322
PENSACOLA, FL 32501-5600
USA
PHONE (850) 439-1999

17 SEPTEMBER 2000

The proposed Revision of the Securities and Exchange Commissionís Auditor Independence Requirements is deficient in one major respect, and, that is that it fails to define the term "audit independence" or "independent auditor." The lack of any authoritative definition in the past has caused the proverbial lack of effective communication on the subject. The following definition of "audit independence" is the only one based on a published, reviewed, and reviewable study of lawmaking documents leading to enactment of the 1933 and 1934 accountant examiner "independent" requirement, and I advise the Commission to adopt it and let all independence rulemaking derive from it:

Free from relationships that a reasonable person

would expect to increase the risk of the accountant

examiner losing judgment-making impartiality.

Committe, Bruce Edward, "Independence of Accountants and Legislative Intent," 41 Administrative Law Review 33,53 (1989).

Respectfully submitted by

Bruce Committe