Comments on the SEC’s Proposed Rule titled “Strengthening the Commission’s Requirements Regarding Auditor Independence”


Comments on the SEC’s Proposed Rule titled “Strengthening the Commission’s Requirements Regarding Auditor Independence” are available here:

https://www.sec.gov/rules/proposed/s74902.shtmlLinks to an external site.

You can see comments by various firms, groups, and individuals, including each of the Big 4, the second-tier and other audit firms. 

Read the submissions of 

  • (a) Deloitte 
  • (b) Ernst & Young
  • (c) Lynn Turner, former Chief Accountant of the SEC
  • (d) Mark Anson, Chief Investment Officer, the California Public Employees’ Retirement System.

https://www.sec.gov/rules/proposed/s74902/deloitte1.htmLinks to an external site.

https://www.sec.gov/rules/proposed/s74902/ernstyoung1.htmLinks to an external site.

https://www.sec.gov/rules/proposed/s74902/lturner011303.htmLinks to an external site.

https://www.sec.gov/rules/proposed/s74902/manson1.htmLinks to an external site.

Required:

Critically evaluate the partner compensation rules from SEC’s FRR No.68 (2003). 

Question:

  • How can the rule be improved? 

Note:

Your answer must include references to the above four comments, but you are free to use material from other commenters.