From: Issaeva, Dessislava (US - Boston) [dissaeva@deloitte.com]
Sent: Friday, August 16, 2002 1:54 PM
To: rule-comments@sec.gov
Subject: CEO/CFO Certification of Financial Statements (s7-21-02)


The purpose and effect of the rule have spurred controversial opinions. 
The commotion is rightfully there, as the practice is unprecedented in 
this country. 

However, this country is, in fact, catching up with the rest of the world,
where management representation in front of the financial package has been 
a requirement for decades. The management statement, that the enclosed 
financial statements are management's representation, and that management 
of the respective company takes responsibility and is aware of this and that, 
appears before any numbers, and even before the auditors' report. In this way, 
the risk of misinterpreting primary responsibility for a wrong balance or 
misinformation is eliminated. The utmost validation of a package of financial 
statements is management's signature on the front page, followed by the 
auditors' report.

Currently, the allocation of representational and informational responsibility 
appears in a couple of sentences in the auditors' report. Hardly anyone bothers 
to read the report, as long as the opinion is clean. For a public relatively 
uneducated about the auditing function, this is a recipe for misinterpretation. 
The current requirement for CEO/CFO certification of financial statements 
should be implemented as regular practice, so that this country finally 
catches up with the rest of the world on more than baseless self-confidence.

Regards, 
Dessi Issaeva 

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