Robert L. Gundrum
4160 Verna Drive
Brookfield, WI 53045
September 19, 2000
Securities and Exchange Commission
Subject No. S7-13-00
I am writing to you regarding an issue, which I believe, has significant negative impact on the entire public accounting service structure to the business community in the United States.
The Commission currently has a proposal on the table for public comment prior to September 25th that will require public accounting firms to discontinue providing "consulting" services to audit or other attestation clients. Their position is that providing these consulting services jeopardizes the CPA firm's independence. I am a CPA currently in the 16th largest firm in the United States. Up until two years ago I was a partner with a smaller local firm of 65 personnel in the Milwaukee area. We specifically joined a larger firm because we could not achieve the size and capital to provide these "non-audit" services which our clients needed to be successful. Our clientele are mostly classified as small businesses, which are commonly recognized as the fastest growing segment in the business community providing employment growth in the United States.
This proposal would currently apply only to SEC clients, however it would be naïve to think that other regulatory bodies would not begin applying the same standards in a very short time. In that event this "SEC standard" would then apply to the entire business community.
The SEC concern regarding independence is not an issue in my practice. We cannot afford to jeopardize our independence because of the negative effect that this would have in the local business community. The favorable standing with banks, attorneys, and local businesses would all be lost with the adverse publicity of a "failed audit".
It is my understanding that the SEC has based its decision to move rapidly forward with this rule without facts to support its position. At the SEC request, a Panel on Audit Effectiveness of the Public Oversight Board was formed. There were no findings that the performance of non-audit services has hurt audit quality. The SEC also admits there is no evidence. Yet the SEC is rushing forward to create regulations which will change the entire profession.
At a time when business is becoming more complex with ever changing technology, it will be difficult to recruit and retain the best talent for audit careers. The young people of today want the opportunity to be challenged and be able to move up to other careers. The public accounting firm of the future would no longer be able to offer those opportunities if the SEC position is implemented.
The real question is whether the SEC should be attempting to determine the cause of audit violations, rather than function as an enforcement agency. I do not believe a negative standard should be implemented that will upset the entire service structure to the business community (both large and small) in the United States. The SEC and the public would be better served by imposing strong sanctions and enforcement when the SEC detects violations of audit standards. This approach would preserve the service structure for not only large companies but perhaps more importantly the many smaller growing companies in the United States.
I would ask that the Commission defer action on this proposal and reconsider its position. It is a proposal that does not serve the public good in the United States. I will look forward to your favorable action on this issue.
Very truly yours,
Robert L. Gundrum