Subject: Comments on proposed on auditor independence rule

Date:    10/25/2000 8:25 AM
     
     
Mr. Levitt,
     
I was most heartened to hear of your proposal for the Auditor 
Independence Rule, as this seems to address a fundamental conflict of 
interest in the large corporate world.
     
However, I am now most dismayed to read that your agency is considering 
severely relaxing this rule, and allowing accounting firms who provide 
both audit and consulting services to merely provide disclosure of same. 
I do not believe this is sufficient, nor do I believe the accounting 
firm's claims that they will have insufficient knowledge of their clients 
to provide adequate audit functions.  You must remember that most large 
corporations utilize the services of several large consulting firms at 
any given time; hence, it's unlikely that any single 
accounting/consulting firm will be the sole provider of consulting 
services, and therefore unlikely that they would have a broad and 
in-depth knowledge of all working areas of the client company.
     
I urge you to return to your original proposal; it is a common-sense 
approach which most investors understand.  Would you agree to have your 
doctor recommend treatment if he also had a significant vested financial 
interest in a pharmaceuticals company - would it be sufficient for him 
to tell you this, or would you rather know that his advice was based 
only his medical ability and that he had his patient as the primary 
concern?
     
Sincerely, Rosemarie Waiand