September 25, 2000
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0609
RE: File No.: S7-13-00
Dear Mr. Katz:
I am the current North American Chairman of Moores Rowland International, an association of independent accounting firms throughout the world. At the most recent meeting of managing partners for this group, I was asked to respond on their behalf to the proposed rules concerning an "affiliate of the accounting firm." We primarily serve small to mid size companies. In addition to the referral of client work to member firms in other regions, some members also join together in industry interest groups that can lead to the development of client services and products. In some cases, firms may have joint marketing initiatives and possible joint venture engagements. Firms may also compete with one another.
As I read the proposed rules and think of how they may be applied by the SEC and how they may be adopted and applied for other regulated industries, I see an endless and time consuming process with little or no merit. Our ability to effectively serve clients as independent auditors could be restricted by the huge costs of compliance with no benefit to those clients or the public. As the proposed definition and rule is written, compliance may in fact become impossible for many firms. In some cases, we may be required to treat a competing firm as an affiliate.
Our North American members object to the proposed rules relating to "affiliate of the accounting firm" and ask that any concerns or recommendations be submitted to the Independence Standards Board for consideration.
DIXON ODOM PLLC
Eddie Sams, CPA