Subject: File No. 4-640
From: Suzanne Hamlet Shatto

November 10, 2011

i listened to the roundtable but i didn't see any panelists who represented the investor.
worse, one of the panelists appeared to depend on "due diligence reports" they get, rather than financial statements.  this comment appears to justify that:
1) financial statements are pretty much useless in demonstrating the position of the firms
2) private information is better than public information.  some of those "due diligence reports" use information not gleaned from public information.
3) auditors do not see their role in representing the public interest.  they go along with management in public statements but do not cause management to give good information to the public nor regulators.
4) there is too much "off-balance sheet" that involves risk, but is not public.
5) that firms may hide and auditors do not disclose.
6) that dodd-frank regulations should bring some along, kicking and screaming.

please continue these conferences at a rapid pace.
i am strongly interested in broker/dealer audits and other dodd-frank regulations, their impact on the market.

i think this roundtable could have taken a different direction but didn't. some of the panelists had very robust comments and seemed to understand the public's interest.  but others didn't.  however, i think their participation could be enlightening, as they will have to come to the point of accepting the public interest and not just thinking that investors should open their wallets for them.  i don't think they should be excluded from future roundtables, but perhaps this is a teachable moment for them.

perhaps you could start with the SEC and FINRA explaining WHY these things need to be done, the inevitability of these regulations.
please do not wait to schedule a new roundtable.  the public needs to watch.  the participants need to give feedback and GET feedback.

this topic was too broad, too theoretical.  it wandered because of that.

suzanne hamlet shatto