Subject: Re S7-10-18 rule comments
From: Elisabeth Rossen

June 3, 2018

General comments:

Re potential for impairment of independence/focus analysis solely on beneficial ownership and significant influence:

Kindly consider  strict criteria for convergence of "related party" transactions And "significance influence" REQUIRING the auditor to immediately resign (or at least replace the engagement partner for one appearing more independent/maximizing "safeguards") and require detailed documentation in work papers and disclosure of the situation with adequate details to protect the public interest.

Feel free to contact me for further clarification of my proposed comments.

Thank you.

Elisabeth Rossen, MBA, MAcc, CFE
Fort Lauderdale, Florida