Comments on Proposed Rule:
Revision of the Commission's Auditor
Independence Requirements
[Release Nos. 33-7870; 34-42994; 35-27193; IC-24549; IA-1884; File No. S7-13-00]
Author: at Internet
Date: 09/08/2000 6:21 PM
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If auditors are so good at their jobs how does a Cendant, Mckesson HBOC,
Waste Management, Microstrategy, IKON Office Solutions, and I can name
many, many more, happen?
Auditor independence is critical to the on-going success of our capital
markets. If the investing public losses confidence in the ability of
auditors to audit private and publicly traded firms the valuation on those
firms most go down as risk loads increase.
You can not convince me that when their is big money involved from the
consulting side of the house that the auditors are not consciously or
sub-consciously affected by it. In fact, I have always been convinced that
the size of the audit fees may be enough to slant how the audit is
approached. My personal opinion is that publicly traded firms should be
required to change auditors every three years.
Mckesson HBOC might have discovered their problems at HBO & Co. earlier. My
understanding is that one of the junior auditors for Mckesson (Mckesson had
acquired HBO & Co. and their firm was a different firm then HBO & Co.'s)
was sending standard letters to HBO & Co.'s clients as respects sales and
the results were not what one would expect. Billions of dollars of market
capitalization was destroyed needlessly. The alleged fraud would have been
discovered sooner or possibly not even have happened if the individuals
involved understood that the auditors due diligence was going to be higher.
What if the auditor discovers that the systems/practices/etc. that the
consultants put in place are flawed or defective? Will they be as quick to
identify them as they might if there were no conflict of interest? Isn't
the fact that we have to question a conflict of interest enough in and of
itself?
The argument that the auditor needs to do the consulting work to understand
better the issues, etc. for a particular client suggests to me that the
accounting firms don't consider their auditing staffs to be bright enough
on their own to understand all the issues as they would affect the audit.
Sorry, I know enough accountants to know that they are intelligent and
curious people who will learn what they need to know to do the audit. And,
of course, they could hire consultants to educate themselves.
It always seems to come back to money. We have substantial rules for
lobbyists, how is it different?
Thank you for inviting my opinion on this very serious matter.
David F. Allen
Author: travis ashby at Internet
Date: 09/08/2000 4:23 PM
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TO: SEC
I support the concept of "auditor independence".
Too much money is at stake. And in our history, nothing has proven to
more often compromise corporate integrity than the bottom line.
Regardless of whether or not it can be proven that a firm or firm's
"consulting" services have impacted the integrity of their accounting,
there is little reason not to separate the two functions entirely.
The only argument in favor of keeping the current system in tact is,
essentially, the "trust us, we're professionals who abide by a code of
ethics" argument. That's not good enough. There are too many people who
have suffered or would suffer on the even rare occasion that ethics
might be comprosmised.
Sincerely,
Travis Ashby
5100 S. Angeline St.
Seattle, WA 98118
Author: at Internet
Date: 09/08/2000 6:46 PM
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The auditor's argument of an absence empirical evidence actually underscores
the problem of not having independent audits. Empirical evidence doesn't get
regularly reported due to the conditions contained in the various settlement
agreements that involve an auditing firm which has negative evidence to
disclose. The cases do settle 95% of the time. The case record is sealed as a
condition. So naturally the SEC investigators would not get the opportunity
to publicly disclose what they know to be true.
For this and other reasons, the SEC must have Auditor Independence to rely on
as the markets continue to grow at amazing rates of speed. Thank You for your
attention to this important rules matter.
John Ashenden, Attorney at Law, 180 N. LaSalle Street, Suite 2500
Chicago, Illinois 60601
Author: at Internet
Date: 09/08/2000 7:18 PM
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Yes, seperate audits and consulting. This is a must and needs addressing
immediately.
Marth J Bredestege
Author: "Jack Burson" at Internet
Date: 09/08/2000 11:39 PM
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In my opinion the independence of any auditor who also renders compensated
consulting services to the company he is supposed to be auditing is ipso
facto fatally compromised. The auditors responsibility should be to
critically examine the accounting records and primary daily financial
records of the company to determine if there any discrepancies between the
two. Then the auditor should insure that the public financial statements of
the company accurately reflect its true condition. An auditor cannot perform
this responsibility if it is simultaneously a vendor of consulting services
to the company being audited.
Sincerely,
I.Jackson Burson, Jr. jackburson@hotmail.com
Author: "CHRISTENSEN;EMORY (HP-Boise;ex1)" at Internet
Date: 09/08/2000 4:26 PM
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I understand the SEC is currently struggling with the issue of audit
independence. As a very experienced private investor, I share the concern of
the SEC. Firms who do "independent" audits, should not be allowed to provide
consulting services at the same time. There's just way to much opportunity
for "subtle" influences.
I support SEC chairman Arthur Levitt's proposal to require separation of the
two.
Regards,
Emory Christensen
Boise, Idaho
Author: at Internet
Date: 09/08/2000 7:12 PM
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I believe, as a common investor, that there is certainly a conflict of
interest where auditing and consulting are concerned. If an auditing firm
would like to extend its relationship with a client into consulting, it
should find an auditing replacement. I'm sure cooperation in the accounting
industry is not common, but it's time to start. If PWC sees a longer-term,
more lucrative relationship with a client in consulting, it should divert the
auditing to one of its competitors who do not have a relationship with that
client. I feel that, much like analysts and underwriters in securities,
where money is involved it is easy to commit fraud. To bag a big consulting
deal, it is possible that an auditing firm may intentionally overlook or
cover-up accounting misdealings. And even the possibility of misdealing
should be enough to stop the possibility of conflicts from ever rearing their
ugly head.
I say that each accounting/consulting firm can only do auditing or consulting
for a client, not both ... the fallout from accounting firms who must drop
one or the other should keep revenues somewhat constant within the industry
and should actually make them more efficient as they may and should
concentrate on what they do best ... it will just make the firms a little
more aware.
Sincerely,
Allen Dahm
Author: "George E Dath Jr" at Internet
Date: 09/08/2000 6:40 PM
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I think it is extremely critical that Auditors are independent of the company
they are auditing. That is, if the auditing company is doing business with the
company being audited, it should not be allowed to conduct the audit. At the
minimum, they should be required to completely disclose any non-audit related
business. If that is permitted, perhaps the SEC should set rules designed to
make the relationship very visible to stockholders and even set permissible
guidelines. The best option though is to tell them they must get a different
firm to do the audit.
G. Dath Jr.
528 Lost Lake Rd.
Arlington, VT 05250
Author: "Dermer; Jeffrey" at Internet
Date: 09/08/2000 2:49 PM
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To Whom It May Concern:
I am writing to voice my opinion on the proposed limitations on auditor's
ability to provide consulting services.
I believe that is very important to tread warily on this issue. At first
blush, it may look like a good idea. However, we must ask ourselves, what
will the end result be?
Will most accounting firms be split into separate entities, one for auditing
and one for everything else? Probably. This will add costs to all users of
financial statements by reducing economies of scale. It may reduce costs to
users of financial statements that have had the specific statements that
they have relied on compromised. It is really hard to say which would be
greater.
I think that of greater importance is what will the result be on the quality
of audited financial statements. More than likely, due to the limited
growth in the audit field, we will see a massive consolidation into one or
two major firms. The cost of audits will go up due to increased pricing
power, while the incentive to provide quality work will diminish as the
market will likely be split into just 2 or 3 firms. Further, will the
self-dealing really disappear? Auditors will continue to have a conflict of
interest with the firms they audit. They will still want to retain the
business and they will be forced to balance future income against
professional ethics.
This is not meant to be a thorough analysis. One thing is certain, we ought
to be loathe to interfere with the free market, unless external costs are
being created. I am not convinced that this is the case. Probably a better
solution would be to increase the protections for whistle blowing within the
large accounting/consulting firms and increase the level of sanctions in
order to increasingly deter undesirable behavior on the part of accounting
professionals. Perhaps the SEC/AICPA could provide databases with
complaints against particular accountants and/or firms, in order to increase
the quantity and quality of information available to the public.
I believe, as a student of law and economics, that the public interest is
better served by less government intervention and increased transparency as
well as stronger fiduciary duties on the part of upper-management.
Ultimately, it is management that is responsible for fraud and auditors can
only be accomplices to it. While a quick fix might seem appealing, I do not
truly believe that the SEC will end up with the desired result while
accruing significant costs to the accounting profession as well as all
publicly traded companies in the form of higher fees.
In the spirit of full disclosure I will tell you that I do not work for an
accounting firm but I am a trained accountant with a background in law and
economics.
Regards,
Jeff Dermer
Author: Jason Dufair at Internet
Date: 09/08/2000 4:48 PM
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I applaud your efforts for independence in auditing and urge you to
proceed with your efforts in this area. Your efforts regarding
selective disclosure were very welcome - keep up the great work.
--
Jason Dufair - jase@purdue.edu
765-496-1185
My grandfather once told me that there were two kinds of people:
those who do the work and those who take the credit.
He told me to try to be in the first group;
there was much less competition. -- Indira Gandhi
Author: "Mike Dyer" at Internet
Date: 09/08/2000 2:42 PM
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I am in complete support of the SEC's position in demanding Auditor
Indepence from other services rendered to Client companies.
Regardless of the evidence, or lack thereof, it only makes good
sense to ensure that an Auditor has no conflicts of interest by
having other dealings by which they would financially benefit from
the company which they are tasked with auditing.
Michael R. Dyer
Author: "Barb Gibbens" at Internet
Date: 09/08/2000 3:58 PM
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As an individual investor, I strongly support an SEC rule that would prohibit
accounting firms from auditing the books of corporations for which the
accounting firms also consult.
-- Barb Gibbens
4167 Poudre Canyon Highway
Bellvue, CO 80512
(970) 224-9389
Author: "Brent Goodwin" at Internet
Date: 09/09/2000 9:34 AM
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As a private investor and also business owner, I can easily see reason for
concern and would strongly urge that conflicts of interest be eliminated (as
much as possible) from the auditing of companies financials. After all,
accountants are also in business and must take the route that is the most
profitable to their firm and if auditing is a "necessary evil" but not as
lucrative, yet helps build their consulting business, well the choices become
too easily weighted to dropping the auditing ball.
Dr. Brent Goodwin
Author: The Hatfields at Internet
Date: 09/08/2000 5:35 PM
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Dear SEC Representative,
I agree with the concern of the SEC regarding the status of
independent auditors who also consult with the clients they are
auditing. I believe that even the most moral of individuals are
placed in an awkward situation when asked to perform the task of
ensuring accurate financial records with a client that also supplies
the auditing firm with considerable sums for other business services.
I agree with the comments made by John Bogle and others that although
evidence of deceit is not clearly available, common sense dictates
that the pressure to commit wrong certainly exists. It will happen,
if it has not already happened.
As an independent and novice investor, I applaud the work of the SEC
to level the playing field for those of us who do not have first-hand
access to business leaders and transactions. We cannot possibly
compete without your work on our behalf.
Peggy Hatfield
Madison, WI 53705
Best regardsAuthor: "Daniel Hegglin" at Internet
Date: 09/08/2000 2:59 PM
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Hi,
On the topic 'The SEC would like to see accounting and consulting services
kept separate to prevent conflicts of interest.' I vote in favor of this
proposed rule.
dan
Daniel Hegglin
Riverstone Networks
5200 Great America Parkway
Santa Clara, CA 95054
(408) 878-6526 - work
(925) 736-4474 - home office
Author: "Kristian Holvoet" at Internet
Date: 09/08/2000 6:12 PM
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Dear SEC,
It is improper for auditing firms to provide other services to the audited
company. It violates the STATED independent nature of the auditor. I fully
support new regulations that limit the relationships between the auditor and
businesses in question. I have no doubt that there have been violations of
trust that have hurt individual and institutional investors.
Please move to protect the investor's (true owner's) rights.
Sincerely,
Kristian Holvoet
Author: "Robert Jennings" at Internet
Date: 09/08/2000 6:27 PM
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SEC
As a beginning individual investor, I strongly endorse your proposal to regulate
auditors who also perform consulting services. I am a government auditor and, by
policy, am not allowed to make recommendations on measures to comply with
deficiencies I have identified because it is clearly a conflict of interest.
Clearly, auditors should be independent of profit motives.
At the least, strong firewalls should be established in such firms with duality
of purpose, such as that in brokerage/banking/merger company arena.
Robert Jennings
Harrisburg, PA
Author: "George R. Jenson" at Internet
Date: 09/08/2000 2:39 PM
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Whether or not empirical evidence can be found of improper audits being
done by the same company that is doing consulting, the two should be
separated, purely because there is a clear conflict-of-interest that could
threaten the sanctity of the audit. Investors have a right to expect that
sanctity as it is promised without having to wonder about the same firm
monkeying with the audit to preserve or enhance their consulting business.
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George R. Jenson 520-622-0125 ext 15 / 800-228-7326
Partner, Fraternity Management Group Mob 520-241-5407 / Fx 520-882-5159
744 North Stone Avenue No eternal reward will forgive us now
Tucson, AZ 85705-8351 for wasting the dawn. - Jim Morrison
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Author: "Jeff Kimmel" at Internet
Date: 09/08/2000 6:26 PM
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Keep the auditing and consultant sides separate.
Jeff Kimmel
jakimmel@bellsouth.net
954.965.8231
954.307-7161 Pager
954.967.9020 Fax
PO Box 627
Dania, FL 33004-0627
http://www.SEBrowardHomes.com
Author: "Art Koolwine" at Internet
Date: 09/08/2000 5:37 PM
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As a small private investor, I would like to offer my opinion on the subject of
Auditor Independence.
I fully support the separation of Audit and Consulting, as I believe that there
is a real danger by allowing the two under one roof.
In many cases, the consulting arm will devise methods & procedures and
underlying operational computer systems to support a company's operations. These
are often subject to close scrutiny during audits. Although shortcoming in this
area may not materially affect the reporting of the financial status of the
company, if the auditors were independent, they would be much more likely to be
critical of processes/procedure/systems that, in their opinion, were not
optimal.
Where the auditor & consultant are essentially one and the same, I don't believe
this is likely to happen.
In the long term, this could have an impact on a companies ability to survive in
today's rapidly changing and highly competitive business environment.
Regards,
Art Koolwine
1401 Westmont Drive
McKinney, TX 75070
972-548-1474
Author: Don Kuhlman at Internet
Date: 09/08/2000 3:40 PM
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Hello, I've been reading some information about the
above mentioned item and thought I would send my
opinion to you as an individual investor and citizen.
I believe that auditor's should NOT have any other
motives in performing their audits of public
companies. The auditor should not be working to
discover any issues in a business while at the same
time charging a consulting fee to help this same
business.
By having a vested financial impact in the success or
failure of a public company you would automatically
place your objectiveness, or the appearance of it, in
jeopardy from the standpoint of being able to perform
an honest evaulation of that same company.
I am by no means an expert in this subject, but common
sense should prevail in my opinion.
Thank you.
Sincerely,
Donald R. Kuhlman
Author: "Daphne Yang Lin" at Internet
Date: 09/08/2000 4:00 PM
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As an individual investor, I whole-heartedly support any efforts the SEC would
make to mandate that auditing & non-auditing (e.g., consulting) services for
publicly traded corporations be handled by independent firms. Although there
may be barriers to full disclosure as to the severity and extent of compromises
that can arise from these intermingled relationships, common sense dictates that
separation of service providers is an absolute must. I think abuses do exist
and have gone unchecked far too long. I applaud the SEC for taking steps to
protect public interest in this matter.
Daphne Yang Lin
Los Angeles CA
Author: at Internet
Date: 09/08/2000 7:06 PM
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Please pass this rule about independent auditors.
Daniel Metsch
Aventura, FL 33180
Author: Jose Plasencia at Internet
Date: 09/08/2000 3:04 PM
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Just to let you know that I am for the approval of the rule.
Jose Plasencia
Author: "Camille P. Potts" at Internet
Date: 09/08/2000 5:52 PM
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I am an individual investor who wants integrity in the stock market to
be maintained by independent auditors.
Camille Potts
Author: "William Prescott" at Internet
Date: 09/08/2000 4:04 PM
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SEC...
As an individual investor I applaud your stand on the potential conflict of
interest that "independent" auditors have between auditing a company and
simultaneously serving as a consultant. The temptation to "shade" the numbers is
too great.
Whenever I cast my votes on the annual proxy statement I invariably vote against
retaining the same auditor.
William Prescott
Author: Dale Quigg at Internet
Date: 09/08/2000 5:51 PM
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Please continue with your efforts to reduce possible temptations audit firms
may encounter when they are also actively engaged in consulting work for a
company.
Thanks,
Dale
Dale Quigg
Aspen Technology, Inc.
425.492.2385
Author: at Internet
Date: 09/08/2000 6:46 PM
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I am in favor of enacting regulations to separate auditing functions from
consulting functions.
Sincerely,
Richard W. Reeks
Author: "Richter; David" at Internet
Date: 09/08/2000 2:56 PM
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I support the SEC in your objective to legislate auditor independence. It
seems nearly impossible that auditors would not be influenced by lucrative
consulting contracts for the same organization. I appreciate the SEC's role
in making the US markets the most trusted domestically and internationally.
Auditor independence would significantly enhance that trust.
Sincerely,
Dave Richter
fidricht@dof.ca.gov
(916) 445-0211 x.2857
Author: at Internet
Date: 09/08/2000 6:44 PM
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hello,
i am asking for independent audtits by the sec.
thank you,
kimberly sayer
Author: "David J. Smith" at Internet
Date: 09/08/2000 6:03 PM
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In my humble opinion the practice of awarding contracts other than the
contract for audit to auditors should be halted; either the auditors audit
the company OR they provide contract services NOT BOTH - too much oportunity
for preferential treatment, too much temptation to tilt issues in favor of
the company under audit, too many opportunies for graft.
(In a similar vein brokers/banks should be prohibited from trading in
securities when they have received income from practices other than the sale
of securities (eg. financing, IPOs and the like).
David J. Smith
Keep up the good work SEC (I'm a big fan of your pontifications on selective
disclosure).
Author: "Soule; Donald C. (ISFPC)" at Internet
Date: 09/08/2000 4:42 PM
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I am surprised to learn that there is not already a rule requiring "auditor
independence" and am writing to register my strong opinion that the lack of
such a rule seriously compromises my ability to evaluate an enterprise and
invest accordingly. Thanks for listening.
Donald Soule
Dcsoul@ispat.com
Author: Maria Spassoff at Internet
Date: 09/08/2000 2:42 PM
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I absolutely agree that auditing and consulting services from the same
company should be kept separate, or closely monitored. I am a private
citizen with no vested interest in any auditing or consulting firm.
Thank you,
Maria Spassoff
Author: Anjul Srivastava at Internet
Date: 09/08/2000 3:06 PM
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Yes, I wholeheartedly support the proposal to separate auditing activities
from consulting and other activities. To put it more precisely, a company's
auditors should not have any other relationship with the company,
especially, they should not be acting as consultants for the company.
With compliments for being pro-active on this proposal,
Regards,
Anjul Srivastava.
Author: WP at Internet
Date: 09/08/2000 2:42 PM
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I feel strongly that the autonomy of the audit process is compromised
significantly when business interests, outside the audit, are provided
by the auditing company. I strongly support SEC rules forbidding a
companies audit firm from providing any other kind of service to that
company..particular consulting services.
Independent audits need to remain independent. This is not an
accusation of impropriety or wrongful abuse of power, it is a
condemnation of a practice that makes that easily available to companies
in the pursuit of profits.
This does not prevent accounting companies from providing
consultation services, only prevents consulting for the same companies
that they are auditors for. The same number of audits and consultation
opportunities (legitimate ones) will exist. It is just a shuffling of
who consults for who and eliminates the conflict of interest and some of
the shady ones.
Dave Starratt
Author: "Sun; Qing" at Internet
Date: 09/08/2000 5:39 PM
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I support SEC in the matter of auditor independence.
I believe unbiased independent auditors are critical to market order, and
separating consulting from auditors to prevent conflict of interest will be
in the public interest.
Qing Sun
FIRST UNION SECURITIES
Tel: 704-715-1380
Email: qing.sun@funb.com
Author: Robert Tuttle at Internet
Date: 09/08/2000 2:45 PM
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SEC:
I agree with the position you have taken regarding Auditor Independence,
as an individual investor I find it refreshing to know that there is a
form of checks and balances for auditors.
thanks,
--rob
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Rob Tuttle
Motorola, Imaging & Entertainment Solutions
Phone : 480-814-5018
Pager: 1-888-699-8821
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Author: at Internet
Date: 09/08/2000 5:38 PM
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Simply put,
"Auditor Independence" is an idea who's time has come. Let's level the
playing
field by making the "officials" as impartial as possible.
Bob Valente
Author: at Internet
Date: 09/08/2000 6:36 PM
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It is important to separate auditing functions from consulting functions.
Maybe the accounting firms could construct a firewall between the two within
their own firm. But, so far, it appears that they have not done that. If
that's true, then the SEC must address the issue and take action.
Robert H. Weir
http://www.sec.gov/rules/proposed/s71300/0908b01.htm
