Subject: File No. S7-22-99

Date:    11/8/99 2:43 PM
     
     
        As a long time advocate of the CPA's association with Interim Financial
Statements of registrants, I enthusiastically endorse the Commission's 
efforts in this arena.  I have read the Commission's proposals along with 
the proposals offered by the Auditing Standards Board and by the exchanges.
  I would like to make the following comments in regards to the SEC's
proposals.  My suggestions are primarily focused on part B--The Audit 
Committee Report. 
        I would advocate that the verb 'reviewed' be removed from any
responsibility which will be assigned to the audit committee.   The verb 
'discussed' is sufficient for several reasons.  To assigned the verb 
'reviewed' will only confuse the issue as to who actually does what.  We 
will now have the CPA, not auditor in this part of the engagement, 
providing a review of the interim financial statements.   To assign the 
same verb to the responsibilities of the audit committee is confusing.  The 
CPA is 'reviewing' and to use the same verb for the audit committee could 
imply that the audit committee's responsibilities duplicate those of the 
CPA.   
        The proposed amendments to the Statement on Auditing Standards would
require only documentation of the 'discussion' among the CPA, management, 
and the audit committee.  To maintain consistency, I would think that 
'discussion' would be adequate.  Also, by eliminating the verb 'review', 
some attorneys may find the liability issue somewhat less onerous for 
clients who serve on committees.
        In subsequent sections of part B the proposals state that the proposed
amendments would not require the audit committee to perform the review. 
This is also confusing when previous sections have used the word in 
reference to the responsibilities of the audit committee.
        I do endorse the concept of requiring a report from the audit committee.
I have heard the position that the mere provision of a report will not 
affect the audit committee's dedication to effect its responsibilities. 
Audit committees should be comprised of highly qualified members who take 
their charge very seriously and whose charge would not affected by the 
requirement to provide a report.  While the position may have some 
theoretical support, the requirement to provide a report can do no harm to 
an audit committee who has performed its mission with due diligence.  I do 
not think the requirement to provide such a report will deter many from 
serving.   
        Thank you for this opportunity.
     
        Robert Rouse
        The College of Charleston
        (1991-92 Academic Fellow in the Office of the Chief Accountant)