a Floridabased holding company whose subsidiaries are engaged the financial services business throughout the United States would require a complete audit internal controls of every public company ID: 842343
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1 Section 404(b) Sarbanes Oxley 2002 (SOXA
Section 404(b) Sarbanes Oxley 2002 (SOXA). Raymond a Florida-based holding company whose subsidiaries are engaged the financial services business throughout the United States, would require a complete audit internal controls of every public company every year, goes Congress in adopting would impose excessive costs on American business, and 1. not intend annual comprehensive internal controls outside auditors. In Section 404 of SOXA, Congress adopted a provision stated the action
2 s significant additional cost of will h
s significant additional cost of will have direct impact the willingness and through the public capital every additional to participate public capital markets inhibition on capital formation with a corresponding adverse the competitiveness and efficiency the PCAOB, regulator of the accounting charged with of the non-competitive the audit United States with respect reporting companies. over 90% companies are audited by just an oligopoly position with set costs, having of compet
3 itors. a result, competitive pressures
itors. a result, competitive pressures new and unwarranted requirement; in statute has completely eliminated whatever slight competitive in the requires each reporting company to use only its perform this should therefore approves a audit requirement of this kind, it economic windfall to four auditing firms, at the entire American business 3. the Commission persuaded that comprehensive audit of internal controls is require such a report on basis. If the Commission, after eva
4 luating the comments concerns of Americ
luating the comments concerns of American businesses, concludes that there a comprehensive internal controls, there is requires the mandate this an annual process. could remain fully with the requirements statute if annual "attest" report as specifically require a periodic comprehensive the outside once every three years, some other periodic term. Such a have the advantage of cost to America's businesses, at the providing a connection with annual "attest" report. PCAOB-RJF-SEC
5 version 4 that the issue the America
version 4 that the issue the American business community. Commission to the attention that the enormity issue in a that gives effect the intent Congress. Respectfilly submitted, Barry ~"~u~enbraun Senior Vice President and Corporate Secretary cc. Honorable William and Exchange Commission Honorable Cynthia Honorable Harvey Honorable Paul Honorable Roe1 C. Campos Joshua B. Bolten, Director Office of and Budget 725 17thStreet NW Washington, DC 20503 PCAOB-IUF-SEC versi