Subject: File No. S7-06-03
From: Ashley W Burrowes, PhD, FCA
Affiliation: University of Wisconsin

March 8, 2008

Dear Ms Harris

I believe that the proposal to defer the S.404 SOX implementation for smaller companies yet again is not serving the public interest.

I have examined a small random sample of these 'non accelerated filers'.

In two instances the employees numbered 10 and 23 respectively. The chance of implementing effective IC often requiring segregation of duties is nigh impossible in such instances.

Therefore the procrastination period being sought will not provide a pancea but only a palliative which is likely to result in prevarication.

It is obvious from my inspection of this random sample that you must

a:) either recognize that a second class of security exists and alert the public accordingly
b:) alert the relevent exchanges to the fact that many of their listed companies do not conform to third millenium corporate governance expectations and recommend they accomodate the securities of these companies in a 'high risk' category.