March 27, 2013
As the President & CEO of a micro-cap public company listed on NASDAQ, I learned with dismay about the proposed rule to require listed companies to establish and maintain an internal audit function, or hire an outside firm to fulfill the role on an outsourced basis. Others have commented eloquently in response to this proposal and I second those points already made. For me the bottom line is that this rule, if adopted, represents an unambiguous incremental cost burden to small companies like ours with little corresponding benefit to investors. The largest of public companies already have internal audit functions and this would presumably have no impact on them, but the burden of such a rule on the smallest of companies like ours is highly disproportionate to whatever benefit might be gained. We take internal controls and risk management seriously and this rule's implementation would accomplish little to strengthen those inclinations.
David L. Nunes
President & CEO
Pope Resources
19950 7th Ave. NE, Suite 200
Poulsbo, WA 98370