SUMMARIES OF TESTIMONY OF REPRESENTATIVES
OF THE
AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS
AT THE
SEPTEMBER 13, 2009 PUBLIC HEARING OF THE
SECURITIES AND EXCHANGE COMMISSION

Mr. Robert K. Elliott, the Chairman of the AICPA, will discuss the impact of the proposed rule on the ability of the profession to participate in the New Economy. In particular, Mr. Elliott will address the need for a new business reporting model, and the imperative of a new conceptual framework for auditor independence in relation to the rule proposal. Mr Elliott will also comment on the work the Independence Standard Board has performed in the past, in particular in developing an understanding of the issues, and formulating the conceptual framework for a principle-based system of regulation. Further, the unintended consequences of the rule, as proposed, in the context of the future needs of the profession in developing auditing responses to the new business reporting model, will be explored.

Mr. Barry Melancon, the President and CEO of the AICPA, will discuss the AICPA's historic involvement in setting independence guidelines and in promoting audit quality, including support for the important work of the Independence Standards Board. He will present the AICPA's views on the rule proposal and the rule making process. The impact of the rule proposal will be analyzed, with particular attention to non-audit services, the broad affiliation rule, the new proxy disclosure requirements, potential unintended consequences and the lack of certainty. The need for an empirical basis for informed rulemaking, with suggestions for further areas of study and further information to be gathered, will be addressed.

Mr. Harold L. Monk, Jr., Chairman of the PCPS Executive Committee of the AICPA, and managing partner of the Florida based firm, Davis Monk & Company, will discuss the impact of the proposed rule in the context of smaller firms.

Mr Gordon A. Viere, Chairman of the Practice Group B Advisory Committee of the AICPA and managing partner in the Minnesota based firm of Larson, Allen, Weishair & Co., LLP, will discuss the impact of the proposed rule on the mid-sized accounting firms.

Mr. Gary S. Shamis, Chairman of the PCPS Management of an Accounting Practice Committee of the AICPA, is the managing partner of S.S. & G. Financial Services in Cleveland, Ohio and Chairman of the Leading Edge Alliance, a strategic alliance consisting of 27 of American's largest local CPA firms. He will discuss the impact of the proposed rule on alliances among CPA firms.