February 29, 2008
I strongly support the proposed amendment to delay the requirement for an auditor's attestation report on internal control over financial reporting for an additional year. However, I recommend that the delay be extended for two additional years in order that the benefits that may be derived from the SEC's study can be fully evaluated and implemented by smaller companies. Otherwise, there may be insufficient time once the study is completed and published for smaller companies to benefit from the results. If the study is rushed to completion, there is bound to be criticism of the study and its usefulness will be hindered because companies will want to once again "wait and see" if there will be a further delay for more evaluation and studies. I think making the delay a two year delay would give the SEC ample time to do the job correctly and to present the results in a manner that both the smaller companies as well as their auditors can benefit.