Subject: File No. 4-497
From: James B Lipham
Affiliation: Sr. EVP & CFO, TSYS

April 7, 2005

We support the goals of the Sarbanes-Oxley Act, however, we do have the following concerns:

- Auditors are hesitant to advise clients.
- Auditors are going overboard in the scope of testing.
- Auditors are requiring excessive documentation.
- There has been a large increase in outside audit fees.
- Auditors do not have adequate resources to conduct internal control audits.
- Companies are receiving conflicting guidance from external auditors.
- Section 404 has created significant initial and ongoing costs.
- Lack of clarity in interpreting standards under Section 404 and additional guidance is needed from regulators.