Senate Comm., supra n. 25 (Testimony of Ruder) at 6-7.

Similarly Former Chairman Hills observed:

Finally, it must be said on this point that unless one has been subjected to a serious corporate meltdown, you cannot possibly appreciate the enormous discretion that management has under GAAP to present its financial position. By changing depreciation schedules, by using different estimates or by adopting different strategies or assumptions, a company can make enormous changes in its annual income. Management too often makes these "top-level" adjustments without adequate disclosure to the public about how much their current earnings depend on such adjustments. A corporate meltdown in which I was involved three years ago was caused by top-level adjustments that accounted for 40% of the company's total income and led to a corporate admission that billions of dollars of income had been improperly reported.

Senate Comm., supra n. 25 (Testimony of Hills) at 3.

Cf. Norris, Will SEC's Needs Be Met? Not by Bush, N.Y. Times, Feb. 8, 2002 at C1.

See 10 Louis Loss & Joel Seligman, Securities Regulation 4636-4669 (3d ed. rev. 1996).

Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A., 511 U.S. 164 (1994).

9 Louis Loss & Joel Seligman, Securities Regulation 4479-4488 (3d ed. 1992 & 2001 Ann. Supp.).

Senate Comm., supra n. 56 (Testimony of Arthur Levitt, Jr.) at 2.

Wayne, Congress's Scrutiny Shifts to Wall Street and Its Enron Role, N.Y. Times, Feb. 19, 2002 at A1.

See, e.g., 6 Louis Loss & Joel Seligman, Securities Regulation 2977-2980 (3d ed. 1990). (Proposed segregation of brokerage and underwriting in 1930s), 8 Louis Loss & Joel Seligman, Securities Regulation 3618-3631 (3d ed. 1991) (Chinese Wall).