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
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TO: RULE-COMMENTS at 03SEC
Subject: Auditor Independence File No. S7-13-00
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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
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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).