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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.shtml

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.htm

https://www.sec.gov/rules/proposed/s74902/ernstyoung1.htm

https://www.sec.gov/rules/proposed/s74902/lturner011303.htm

https://www.sec.gov/rules/proposed/s74902/manson1.htm

Required:

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

  • What are the pros and cons of the rule?
  • How can the rule be improved?

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

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