From: David Skinner [David.Skinner@mvnu.edu]
Sent: Thursday, November 07, 2002 10:47 AM
To: David Skinner; rule-comments@sec.gov
Subject: Definition of Financial Expert (s7-40-02)

The Wall Street Journal (11/1/02, p. C3) commented on the SEC's proposal 
o require firms to tell investors how many "FINANCIAL EXPERTS" they have 
on their audit committees.  The article continued by describing (1) understanding 
of GAAP, (2) experience in applying GAAP, (3) experience preparing or auditing 
financial statements, (4) experience with internal controls, (5) experience 
with procedures for financial reporting, and (6) understanding of audit-committee 
functions.
 
Assuming the article correctly described the proposal, I would like to suggest 
a change.  I am a PhD in FINANCE with a doctoral minor in ACCOUNTING, and have 
taught finance for over two decades and sometimes have taught accounting.  I 
interact regularly with experts in both finance and accounting.  When I showed 
the article to my colleagues, their reactions were the same as mine.
 
The six points above might be used to descirbe an ACCOUNTING EXPERT or even a 
FINANCIAL ACCOUNTING EXPERT (except possibly for #4 and #6) but would not 
accurately describe a FINANCIAL EXPERT.
 
Perhaps the term should be reconsidered.