Dear SEC Chairman: Some Suggestions.

• Position: Securities and Exchange Commission management - Brief Article

The changing of the guard in Washington offers a time for new approaches in many areas. Arthur Levitt served as SEC chairman for longer than any of his predecessors. During his tenure, our capital markets and economy experienced huge changes that now require a new agenda. Here's my list of issues that should be at the top of the agenda going forward.

* The SEC can play a role in moving the markets away from a short-term, quarterly focus, whereby companies are rewarded for careful attention to quarterly results, often at the expense of long-term investment. While most companies embrace the challenge to perform for their stakeholders, the truth is that this systemic problem has been brought about more by the hype and self-promotion of market-makers that imply some competitive benefit from a short-term information advantage.

* 10-Qs and 10-Ks are obsolete. The amount of information available to investors is up exponentially over the past decade. User-friendly publications, analyst reports, television and Web sites are now the predominant sources of investor information. During that time, SEC filings have gone the other direction. New disclosure requirements have been piled on top of outdated ones. Boilerplate language abounds, as the governing rules themselves also have gotten more onerous. We need a zero-based look at what will make up a useful and readable set of SEC filings.

* Don't react to individual problems, only systemic ones. Ton often in the past, a good media story or potential media attention has been a spur to considering new regulation. Let's have a more rational environment where one or two problems, like Orange County's internal control derivative breakdown, doesn't lead to complex, burdensome regulations like FAS 133 that will sap corporate resources without adding to investors' understanding of the company.

* The media continues to try to reopen stock option accounting. Options are impossible to measure fairly and are uniquely important to our economy, and the compromise of existing disclosure requirements is confusing and bad enough without further polluting financial statements. The amount of stock options given to employees is a governance matter between shareholders/owners and their managers. They don't need dictums from those not party to the relationship.

* The marketplace would welcome a transitional plan moving toward acceptance of global accounting standards that are recognized by the SEC. Today, there are 40...