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U.S. Securities and Exchange Commission

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: "Brian Currie" at Internet Date: 10/03/2000 11:58 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Auditor Independence File No. S7-13-00 ------------------------------- Message Contents Dear Sirs I sent my written testimony on 25 September by email in html format. I don't see any sign of it on the public record - which I had expected. Did you receive it? Any problem? Brian Currie Brian@Currie.co.uk


Author: "Anil K. Thomas" at Internet Date: 10/03/2000 12:31 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-13-00: Revision of the Commission's Auditor In ------------------------------- Message Contents I realize the comment period for this rule has expired. However, I would like to suggest a simple rule: Any fees paid to an auditor for non-audit services must be disclosed in the footnotes. I envision something like this: The auditor has performed the following services for ABC Corporation for the year ended XX/YY/ZZ: Audit servces $___________ Consulting services $___________ Bookkeeping services $___________ Tax services $___________ This disclosure would allow the readers to judge for themselves if independence has been compromised. Whether or not there are actual proven cases of non-audit work influencing audit results, there is certainly sufficient doubt to warrant such disclosure. Notes: 1. In addition to the nonaudit fees, the audit fees must also be disclosed, so the relative value of the audit engagement can be judged. 2. The disclosure might be made as part of the "Related Parties" footnote. 3. If not in the published report, it can at least be required in the SEC filings (such as the 8k).


http://www.sec.gov/rules/proposed/s71300/1003b01.htm


Modified:10/05/2000