February 27, 2007
To Whom It May Concern:
Additional guidance to management as to implementing and assessing a proper, working framework of internal controls should be given. The regulations as currently in place put the balance of power in assurance services squarely with auditors, as opposed to creating a symbiotic relationship with service provider and client. A great deal of this results from the lack of specificity in the principles. In the absence of such detail from the Commission, the accounting firms have created their own detailed programs which do not significantly vary from each other. However, this is not an indication of the detail the Commission intends, only of the accounting firms interpretation of what the Commission intends. Clearer guidance can work better than the process currently in place and help non-accelerated filers effectively implement and assess their control structure.
Thank you for your time,
Ayal Rosenthal