September 25, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-0609
Re: Proposed revision of Auditor Independence Requirements
SEC File No. S7-13-00
Dear Mr. Katz:
The Office of the State Treasurer of Oregon supports the proposed rule amendments to 17 C.F.R. Parts 210 and 240 concerning auditor independence.
At any given time, the state has invested in publicly traded stocks tens of billions of dollars of Oregon Public Employees Retirement Fund and other moneys. Like others such investors, our "active" investment managers rely in part on the audited financial statements of the issuing companies.
Auditor independence is necessary to assure that those financial statements provide reliable information concerning the financial status of the companies. We believe that the Commission's proposed rule amendments will protect investors by assuring that the other business objectives of the auditing firms are not in conflict with the duty to audit financial information consisting with generally accepted auditing standards and by disclosing information about non-audit services provided by auditors.
If we may provide the Commission with additional information that may assist it in the consideration of this important matter, please advise.
W. Dan Smith
Director - Investment Division