From: Peroni, Paul J [Paul.Peroni@bellsouth.com]
Sent: Tuesday, December 31, 2002 10:47 AM
To: 'rule-comments@sec.gov'
Subject: S7-49-02 

Dear Mr. Katz:

This comment is in regard to the proposed rule for periodic forensic audits.

Rather than requiring the engagement of independent forensic auditors, the
Commission should require company internal audit departments to perform
detailed forensic financial audits in addition to traditional operational
audits.  

Internal auditors are more familiar with the operations of the organizations
they are employed at and the addition of permanent forensic
accountants/auditors would complement their efforts.


Paul J. Peroni, CPA
Internal Audit Project Leader
BellSouth Corporation    


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