From: Randolph Caldwell [eurovol@email.com]
Sent: Thursday, November 21, 2002 5:26 AM
To: rule-comments@sec.gov
Subject: Proposed rules on audit reform

As this was only annouced 19 NOV 2002, I have not found it on your 
website with a reference number.

My name is Randolph B Caldwell and I am a Scientist working towards my PhD.  
There is an oversight committee for science in the US Office of Research 
Integrity.  I suggest you not re-invent the wheel, but adapt similar 
guidelines for the accounting industry.

Audit documents should be held ten years and copies of dissenting opinions 
should be filed with the SEC by the company's audit committee with CEO/CFO/COO 
comments and should also be included in annual reports .

If there is transparency, then there is no need to mandate the time a single 
accountant/auditor can work for a client.  This should be raised one step to 
perhaps three year in-depth reviews of the accountants work by the company's 
audit committee and a third party auditing firm.  This would bring in a fresh 
face every three years to audit the auditor.  A job now needed by all the out 
of work auditors.

The company's audit committee should be 50%+1 independent of the business of 
the company.  This board of audit should report directly to the board of 
directors.  The board of directors should be the ones ultimately responsible 
for company positions.

If the chain of command/responsibility is followed and transparent, there will 
be no need to "over-regulate".  Simply organise and open the process to public 
and peer-review.
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