Support Senator Gramm Amendment to S. 2673

July 11, 2002

To Members of the United States Senate:

The U.S. Chamber of Commerce, the world's largest business federation, representing more than three million businesses of every size, sector, and region, would like to state its support for Senator Gramm's amendment to provide the Public Company Accounting Oversight Board with appropriate flexibility in applying non-audit services restrictions to small business under S. 2673.

Under the Gramm amendment, the Public Company Accounting Oversight Board would be given authority, by rule to exempt any person, issuer or accounting firm taking into consideration factors of the assets size, availability and cost of retaining multiple service providers, number of public company audits performed, and other factors as deemed appropriate.

More than 96 percent of the Chamber's members are small businesses with 100 or fewer employees. The provision in S. 2673 requiring separation of audit and non-audit functions will be difficult for any but the largest companies to comply with. We do not support any provision that would ban a company from freely choosing the accounting firms it deems most suitable to providing non-audit services. Smaller, non-public companies would be especially overburdened with additional cost to comply with this provision. Many of these firms are limited by location to adequate resources to comply and the complexity would overwhelm smaller firms as they struggle to meet existing financial reporting requirements. This would hurt smaller companies' profitability and their ability to grow and create jobs.

We urge the Senate to support the Gramm small business exemption amendment and thank you for your continued careful consideration of this.

Sincerely,

R. Bruce Josten
Executive Vice President, Government Affairs
U.S. Chamber of Commerce