First of all, I want to make it very clear that I heartily endorse the Commission’s focus on independence. It’s absolutely critical to the interest of investors, and therefore the public interest of the United States.
I particularly support the provisions onproviding — against providing non-audit services to audit clients. And I’ve heard, to be honest, and read nothing today to change that view and, indeed, quite a bit to reaffirm that.
Of course there is no clear evidence on this subject, but as your proposal says, your rule proposal says very aptly studies cannot always confirm what common sense makes clear.
I know it’s subtle. I know it’s a state of mind. But when self-interests predominate, trouble comes not far behind. And it seems to me it comes into special focus as a profession becomes a business.
In this case, the profession of accounting turns into the business of consulting and cross-selling. It’s potentially very adverse consequences to the public interest. Actually, to be honest, I forget who brought this up, maybe Commissioner Carey, the distinction.
When I talk about is business and profession or profession and business between church and state might not actually be too far from the mark.
If you’ll forgive me if I add a parallel to my ownexperience in the mutual fund business, which used to be a business of trusteeship and investment management and has now become a business of marketing, and the public interest, in my judgment, has not been served thereby.
Now turning to the other services, you’ve heard from my fellow members of the ISB on the subject, so I won’t add too much to that except to say that those other services of a significantly different dimension, in my view, should best be left to the Independence Standards Boards.
The rules you have here parallel those we’ve put together, and we put them together, I think, in a very constructive, deliberative and positive, remarkably positive process with the participation not only of the public members here represented, I found the professional members, the members of the auditing profession, to be singularly helpful putting some practicality to what we’re talking about, and we’ve also had terrific participation from Chief Accountant Turner and your own staff in putting together rules that I think are pretty good.
We’ve actually come and reasoned together and brought out reasonable rules that will help the public interest. And I think conflicting rules or even a conflicting rules structure will vitiate the ISB mission.
So I hope the Commission will consider strengthening the ISB perhaps even by a larger public representation on that board.
Finally, I want to add two cautions based on some of the things I’ve heard today. First, do not overestimate the value of disclosure. It is necessary. Your release has it exactly right. But it is not sufficient to rectify the kind of problems we’re talking about here.
I hear these opinions that these issues will all be worked out on the wonderful stock market. Let me assure you the stock market is imperfect.
The stock market is flighty, and these issues are but only one set of issues and but no means the most important of an infinite number of issues the stock market takes into account in valuing companies. And there is no way to find much linkage in my own experience.