From: Craig Glynn [craigglynnus@yahoo.com]
Sent: Thursday, January 09, 2003 4:35 PM
To: rule-comments@sec.gov
Subject: S7-49-02

United States Securities and Exchange Commission
Washington, D.C.
 
Ladies and Gentlemen:
 
The recently proposed rules on auditor independence contain provisions 
for rotation of audit partners that go well beyond those contained in 
the Sarbanes-Oxley Act.  The purpose of both the proposed rules and of 
the Sarbanes-Oxley Act is to increase corporate responsibility and to 
restore investor confidence.  As an investor, I am not at all convinced 
that rules requiring a rapid rotation of all senior personnel (partners) 
on audits will have the desired effect.
 
The proposed rules would make it extremely difficult for all but the 
largest of CPA firms to conduct any audits of SEC registrants.  Currently, 
although audits of large companies are dominated by the largest four 
auditing firms, the audit of all public companies in the United States 
is a task ably performed by auditing firms of all sizes.  The rapid 
rotation of all partners involved in any public company's audit would 
present smaller firms with an impossible task.  I do not understand how 
driving smaller firms from the market will increase either investor 
confidence or corporate responsibility.
 
The proposed rules would result in inexperienced audit personnel on the 
very engagements requiring experience.  The large (Fortune 1000) companies 
in the United States today operate in complex business environments and 
often have numerous subsidiaries.  Further, these companies must comply 
with accounting guidance, and regulatory rules and laws governing many 
aspects of their activities, the documentation of which numbers into the 
thousands of pages.  If auditing firms are required to rapidly turnover 
the more experienced auditing personnel (partners) involved in the audit 
of each subsidiary, the obvious result will be the assignment of less 
experienced personnel to the audits of complex businesses governed by 
complex rules.   I do not understand how investors in large companies 
will be better served if audits of those entities are conducted by 
personnel having less experience and familiarity with the operations of 
these large and complex businesses.
 
As a CPA and former auditor - though not currently involved in the auditing 
profession - I can better gauge the impact of the proposed rules than most 
investors.  However, I write this as an investor who would like to think 
that the SEC will issue rules consistent with the Sarbanes-Oxley Act (that 
is, require rotation of only the lead partner and the concurring partner, 
as required by the Sarbanes-Oxley Act), and with the goals of increased 
corporate responsibility and heightened investor confidence.
 
Yours truly,
 
Craig T. Glynn
Craig T. Glynn
868 14th Street
Manhattan Beach, CA 90266
Mobile 310-200-4526
FAX 310-796-1297
craigglynnus@yahoo.com

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