-----Original Message-----
From: Toni Britt [toniandrickbritt@mindspring.com]
Sent: Friday, July 12, 2002 9:16 PM
To: rule-comments@sec.gov
Subject: Comments on Changes (s7-24-02)

I am a practicing CPA, Litigation Support and Forensic Accounting, and am the retired Chief,
Criminal Investigation Division, Internal Revenue Service after 28.5 years with the Internal
Revenue Service.  You may see my bio at RYBD.com, look under client services and litigation
support.  You will also find me under the Association of Former Special Agents of IRS and at the
Association of Certified Fraud Examiners.

It is strange to me in all of the changes you are proposing, it does not appear you have consulted
with persons like myself who have investigated thousands of all types of white collar crimes.  You
rely on theoreticians and academia, but you do not ask the people who have the most experience-the
investigators!

I offer myself, and I am sure I can find many of my colleagues who could help you materially in
forming the type regulations and organization that could prevent much of the problems encountered.
Financial Statements waste so much time with form over substance.  The real issues that need to be
addresses, like internal controls, ethics and auditing and policing are and have been treated
almost as an aggravation.

Idea men, prestigious business schools and even the government treat controls and those who are
charged with the responsibility to protect and safeguard assets as a bother and nuisance.  In
other words rainmakers can't be bothered by bean counters.

Bean counters who are progressive and experienced should be in the control chairs in business and
government.  There is no substitute for experience and doing things the way the laws and
regulations require.

Our entire business psyche needs to come somewhere in the middle between the rainmakers and the
bean counters.

It is a sure thing that the rain makers have certainly made us all wet recently!  If we had
listened more the technocrats and bean counters, we would at least have more beans!

William R. Britt, CPA    
1645 Rockdale Circle
Snellville, Georgia 30078