From: Jason Zahner [jzahner@gbronline.com]
Sent: Monday, December 23, 2002 2:59 PM
To: rule-comments@sec.gov
Subject: file # s7-49-02 due Jan 13

Comments File # S7-49-02

Regarding Auditor Independence

The SEC is addressing a unique problem, which it could entirely solve 
by removing all subjective criteria from its language.  Essentially the 
cleanest way to ensure independence is to: 

1.	Not allow the auditing firm to have any non-audit work during an 
audit year.

2. Rotate audits every 3 years and not repeat auditing firms for at 
least 10 years after an audit rotation ends.

Non-audit work related to any client could be picked-up after an audit 
rotation has ended.  I would encourage 3-year rotation over 5-year 
rotation to ensure the auditing function becomes almost standardized.  
Standardization would encourage simplified FASB standards and transparency 
in financial statements.  Firms could have tax, audit, and consulting 
practices, but if an audit is performed for a client, no other work is 
allowed that audit year for that client.  I think this is a very simple 
and effective method to ensure independence is maintained.  All firms who 
have the ability to practice before the SEC would be potential auditors 
and no one firm could be colluded with.

The SEC has become overly complicated in recent years in my opinion and 
simplification could solve all of this.


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Jason Zahner
(321) 773-7186
jzahner@gbronline.com
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