April 4, 2005 Mr. Jonathan G. Katz Secretary U.S. Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549-0609 File No.: 4-497 Feedback on Experiences with the Implementation of the Auditing and Reporting Requirements of Section 404 of the Sarbanes-Oxley Act of 2002 Dear Mr. Katz: The Center for Public Company Audit Firms (the “Center”) of the American Institute of Certified Public Accountants (“AICPA”) is pleased to have the opportunity to submit feedback on experiences with the implementation of the auditing and reporting requirements under Section 404 of the Sarbanes-Oxley Act of 2002 (the “Act” or “SOX”). The Center was established by the AICPA to, among other things, provide a focal point of commitment to the quality of public company audits and provide the Securities and Commission and the PCAOB, when appropriate, with comments on their proposals and/or feedback on the implementation of new requirements under the Act on behalf of Center member firms. There are approximately 900 firms that audit 97% of all SEC registrants. Sixty-six firms (including the largest 8 that are Center members) audited registrants that filed 404 reports with the Commission as of the date of this letter; 64 of these firms are members of the Center. All of the Center’s member firms are U.S. domiciled accounting firms. The AICPA is the largest professional association of certified public accountants in the United ...