August 18, 2000
Commissioner Laura S. Unger
As a practicing Certified Public Accountant in Ohio for 20 years I am concerned by some recent proposed rules promulgated by the Securities and Exchange Commission. These rules would limit the ability of a CPA to provide our clients, either public or nonpublic entities, the necessary business services that our profession has worked so hard to develop and train ourselves in. I believe, that the public desires our services because of the trust and integrity that our profession, for the most part, has earned.
For a CPA To effectively audit an entity, the auditor must understand the business and industry, culture, people, systems, risk considerations and virtually everything of a material nature involving the entity. As a result, the entity naturally and wisely turns to the CPA for advice.
The profession has done a wonderful job in setting standards for CPA's in training, education, and competence in fulfilling the responsibility to perform audits that the public can trust and value.
I believe that these SEC initiatives are flawed for the following reasons;
I believe regulation has a place when it is well thought and targeted to help the public. I believe that this is not one of those times.
Thank-you for your consideration regarding this matter.
Very truly yours,
HOLBROOK & MANTER, LLP
Bradley H. Ridge, CPA