March 9, 2008
Nancy M. Morris
Secretary, SEC
100 F Street, NE
Washington, DC 20549-1090
RE: Comments on File S7-06-03
Dear Ms. Morris,
I first want to thank you for allowing me this opportunity to comment on the proposed amendment. I have a few comments and concerns regarding this proposal.
I believe the study that is being undertaken will be a good determinant on the cost-effectiveness for smaller reporting companies. It is important the Sarbanes-Oxley be implemented as cost efficiently and effectively as possible. It is also important the guidance offered to auditors of smaller public companies is done effectively, so that when the extension period is over, the non-accelerated filers will be ready to comply with the auditor attestation report requirements. The guidance offered may reduce auditors fees that usually represent a large percentage of the overall cost incurred by smaller public companies. It may also allow public companies to strengthen their ICFR evaluations.
I believe this should be the last extension for non-accelerated filers. Non-accelerated filers have had plenty of time to develop a plan to comply with the auditor attestation report requirement in Item 308(b) of Regulation S-K. After the study is done and the guidance takes place for auditors, smaller public companies should be more than ready to comply with the attestation report requirements.
I believe non-accelerated filers should be required to provide their auditors attestation report along with the management report in their annual reports. If this is done, it will help determine if the company is in compliance with Section 404 requirements.
Another concern I have is in regards to the cost non-accelerated filers may incur. I believe these costs are fallacious because they are only thought of as bringing a burden to the company, but in all actuality they are benefiting the company. Once these costs are incurred, companies will finally comply with Section 404 which will give the public faith in the company.
In conclusion, I agree with the extension for only another year. I believe the extension will allow smaller public companies the ability to fully comply with attestation report requirements.
Sincerely,
Melissa Palmer
2008 Accounting Graduate
University of Wisconsin- La Crosse
melissarpalmer@gmail.com