From: Bruce Rosen [BRosen@eisnerllp.com]
Sent: Friday, January 10, 2003 3:58 PM
To: Rule-comments@sec.gov
Subject: S7-46-02

It would help if the final rule could provide some examples of 
"workpapers" that have to be saved and those that can be discarded.  
Some examples could include:
 
Prior drafts of financial statements where footnotes are written by 
clients or younger audit staff, and are edited as they are reviewed 
by more senior people
 
Schedules and analyses provided by clients, but not used by the 
auditors
 
Superceded schedules and analyses where the original schedules are 
updated during the audit
 
Practical examples would avoid the saving of large amounts of 
"workpapers" that meet the two criteria of (i) provided during the 
audit and (ii) containing analyses or financial data, but really 
don't contain a discussion of issues and opinions. I recognize that 
there may be an instance where a schedule or analysis changes as a 
result of a discussion of issues or a change of opinion, but if that 
does happen, what I think you really want saved are the memos and 
e-mails discussing the issue.
 
If this does not get addressed in the final rule, please consider 
for a FAQ.
 
Thank you,
 
Bruce Rosen