Colorado Society of Certified Public Accountants
7979 E. Tufts Avenue, Suite 500
Denver, CO 80237-2843
September 25, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
Dear Mr. Katz:
I am writing on behalf of the Public Company Practice Committee of the Colorado Society of CPAs, of which approximately 50% of the Committee members are in public practice and 50% are CPAs from industry. Our members represent a good cross section of CPAs practicing in the public arenas in the United States.
The Committee met on September 19, 2000 and discussed the SEC's proposed rule regarding revision of auditor independence requirements. While there are parts of the proposal that the Committee would welcome, the rule has dramatic and far-reaching implications affecting the accounting profession and deserves more time for thoughtful deliberation. We urge the Commission not to adopt its proposed rule but rather to allow the necessary time for thorough consideration and discussion among all interested parties - the SEC, the Public Oversight Board, the accounting profession, and the public. The conclusions and recommendations of the Panel on Audit Effectiveness' should not be ignored, and we ask that the Independence Standards Board be allowed to do its work in creating appropriate standards for independence and scope of services. To adopt the proposed rule and circumvent the bodies already established to identify and develop solutions in these areas is both preemptive and unnecessary.
The subject matter of this proposed rule deserves some serious attention. The members of this Committee encourage full debate so as to allow the existing system to work in protecting the interests of the public.
Very truly yours,
/s/ Lisa S. Wilson
Lisa S. Wilson
Chairman - Public Company Practice Committee