Weaver & Martin, LLC.
411 Valentine Rd., Suite 300
Kansas City, MO 64111
Via Email: rule-comments @sec.gov
December 31, 2002
Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Washington D.C. 20549-0609
Re: SEC File No. S7-49-02
Strengthening the Commissions' Requirements Regarding Auditor Independence
Members and Staff of the Commission:
On behalf of all of the smaller registered companies who mainly do not trade on any exchange and the small CPA firms doing their audits I would like to comment on the proposed rules regarding partner rotation requirements.
We are CPA firm that has two qualified auditors of publicly held companies. We currently do audits of four registered companies and are exempt from the partner rotation requirement of the AICPA SEC Practice Section due to the size of our firm and limited number of publicly held clients. The proposed regulations will effectively put our firm out of the business of auditing publicly held companies and significantly increase the cost of audits for the companies currently being audited by any non national CPA firm.
During the last six months we have contacted over 150 companies with market capitalization under $25 million. We found that the large CPA firms refuse to do audits of companies that are traded on the pink sheets and the bulletin board. These Companies would find it difficult to complete their audits without utilizing a smaller CPA firm. The proposed partner rotation would put a great burden on these companies.
All of the recent audit failures were by the national firms not smaller CPA firms. Yet the proposed regulations are punishing small CPA firms as if were the cause of the problems. Small CPA firms are not the problem.
At a minimum the smaller public traded companies, particularly those companies not traded on any exchange, need at least three years to comply with the regulations in order for them to secure an audit firm. Additionally, the Commission will need to issue regulations to force the larger firms to accept these smaller engagements.
Very truly yours
/s/ Weaver & Martin