From: Keith Jajko [kjajko@nationalnotary.org]
Sent: Thursday, August 22, 2002 2:28 PM
To: 'rule-comments@sec.gov'
Subject: File No. S7-21-02

August 21, 2002



Mr. Jonathan G. Katz
Secretary
U.S. Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

RE:	File No. S7-21-02 (Certification of Disclosure in Companies' 
Quarterly and Annual Reports)

Dear Mr. Katz:

We have been following with considerable interest the Commission's
development of rules for public company Chief Executive Officers and Chief
Financial Officers to use in certifying their firm's quarterly and annual
reports as true and complete.

On behalf of the National Notary Association, I would like to commend the
Commission for its recognition of the importance of utilizing the services
of Notaries Public in the earlier authentication and filing of financial
reports by the 947 public companies who were requested to do so.  The
involvement of Notaries strengthened the credibility of these reports in the
public eye through positive verification of the identity and intent of their
signers.

It is clear that the public is now demanding an accountability on the part
of CEOs and CFOs that the mere signing of a "certification" under penalty of
perjury will not provide.  Without the involvement of a trusted impartial
witness - a Notary Public - to place the executive under oath, the
reliability of any certification could much more readily be called into
question.  As a commissioned officer of the state, the Notary would help to
alleviate doubt and to invest confidence in the process simply by adhering
to the basic solemnities of the oath, stressing to the signer the
seriousness of the document, observing the affixation of the signature, and
documenting all of these facts in a record.   The possibility of a CEO or
CFO evading responsibility by claiming that his or her signature on a
financial statement or annual report was forged, unintentionally made or, in
the case of an electronic signature, created without authorization, would
thus be virtually eliminated.

Throughout American history, Notaries have prevented our court system from
being overloaded with challenges to signatures that have been forged,
coerced or incompetently made.  In this complex age of electronic documents
and digital signatures, there is a clear consensus that the need for trusted
third parties has grown rather than diminished.  Indeed, the virtual
explosion of identity theft and fraud is ample evidence of the damage
wreaked by unchallenged signatures every day in this country. 

We would respectfully urge that, just as Notaries were involved in the
signing of the earlier filings by the 947 public firms, this involvement
should continue with all future federal filings of quarterly and annual
financial reports.

A non-profit educational organization since 1957, the NNA can offer
important information and recommendations on the notarization of both
pen-and-ink and electronic signatures.  Indeed, the soon-to-be-published
Model Notary Act of 2002 provides the first-ever systematic rules for
notarization of electronic signatures, allowing full implementation of the
federal Electronic Signatures in Global and National Commerce Act of 2000
and the Uniform Electronic Transactions Act, promulgated in 1999 by the
National Conference of Commissioners on Uniform State Laws.

If the Sarbanes-Oxley Act's provision requiring CEOs and CFOs to certify
company financial reports as accurate and complete is to have the "teeth"
necessary for meaningful enforcement, we respectfully urge the involvement
of trusted third party state government officials - Notaries Public.

Sincerely,



Milton G. Valera
President







MGV: mss