From: Joseph Spinella [mailto:jnspin@optonline.net]
Sent: Friday, July 05, 2002 12:18 PM
To: rule-comments@sec.gov
Subject: File No. S7-24-02

Dear Mr. Katz:

I think the SEC proposal to establish a Public Accountability Board to audit the auditors is a very
good idea and would strengthen the financial reporting process in the United States. 

Being a CPA in industry for over 20 years I see the problem differently than the SEC. I always
thought the problems that we are now seeing in the press, stem from the personnel practices of the
CPA firms. Most of the big four firms have an informal up-and-out policy. This means that the
auditors doing the work are inexperienced and learning on the job. Once they are trained they are
forced out. In effect companies are paying over $150 per hour for inexperienced auditors. There is
nothing wrong with learning on the job but not at the expense of shareholders and the retirement
funds of individuals. This problem was compounded by the fact that business has become very
sophisticated, and that more experience and education is needed by auditors to do the same auditing
work that was done 20 years ago. The CPA firms answer to the increasing sophistication of business
was to hire less MBA's and more English majors with 2 year degrees. Years ago when an auditor
audited a company he was more experienced and knowledgeable then the client's accountant. Today the
auditors know less then their client's counterparts. This needs to be changed.

If the SEC intends to protect the reliability, accuracy, and confidence of the financial reporting
process, it needs to have experienced accountants / CPA's doing the audits, as well as, the
upcoming audit quality reviews.

Respectfully Submitted,
Joseph Spinella