From: James Biedenbender [James.Biedenbender@gsbbcpa.com] Sent: Tuesday, June 10, 2003 11:13 AM To: rule-comments@sec.gov Subject: Re: S7-10-03 I am a CPA with over 25 years experience in the profession. Given the recent scandals that have been prominently displayed in the press over the last year or so, I believe it is imperative that measures be taken to improve both the quality and the independence of the boards. It may be that one way would be to create a new designation - certified board member. These CBM's would have to have attained specified education requirements and testing. Each board would be required to have a mininum number of these independently paid professionals. These designees would be limited to a maximum of 4 to 6 boards per year. These designees would be monitored by the SEC and would be appointed by it as well. These independent CBM's would be able to have disclosure mechanisms to the SEC that would provide for an "early warning system" that would assist in nipping financial fraud in the bud. It is not supposed to hinder management but rather provide a voice for shareholders and other stakeholders when management pursues financial engineering schemes designed primarily to provide or increase management compensation. Essentially what is required is an improved system of checks and balances.