October 2, 2000

Jonathan G. Katz, Secretary
email: rule-comments@sec.gov
Securities and Exchange Commission
450 5th St. NW
Washington, D.C. 20549-0609

Ref: File #S7-13-00

Dear Mr. Katz,

As a practicing CPA, representing a firm of approximately 50 people, I am greatly concerned, and opposed, to the above referenced rule proposal. The idea of prohibiting CPAs from providing non-audit services to our audit clients is offensive to our profession, counterproductive to the best interests of our clients, and would not accomplish what perhaps is the goal of the reason for this rule being proposed.

Firstly, it is my understanding that regardless of any alleged failings of any of the Big 5 in matters of possible independence issues on audits and the like, despite whatever concerns the SEC might have, in fact there has not been one instance of an actual/real verifiable case of any impairment or quality shortcomings in any of the subject audits resulting as a consequence of the CPA firm also filling a consulting role. Therefore, it would seem you are going in the direction of trying to fix what is not broken, or trying to fix with a heavy hand what perhaps might need merely a fine tuning.

The reality of the services we provide are such that clients are best served when there is a thorough understanding of the client's operations so that all aspects of servicing that client can be intermingled and meshed. There is no conflict inherent in such a situation. Rather, the client gets the best service, and the public is best served, when one CPA firm is involved with multiple aspects of the client. This puts the CPA firm in the position of understanding what is going on, being aware of where problems might occur, and being able to give the client the best service. To force a separation of this good meshing, by in the sense saying that if a CPA firm does an audit another CPA firm must do other various functions, would create a split in the understanding of that client, inefficiencies, and likely weaken the quality of the work. It would also wind up costing the client more.

In summary, I believe the proposed rule is ill advised and should be withdrawn. It is in fact contrary to the best interests of the public, the clients and the accounting profession. It would result in exactly the opposite of what you are trying to accomplish.

Very truly yours,

Kalman A. Barson, CPA
Member of the Firm


c: Senator Frank Lautenberg email: frank_lautenberg@lautenberg.senate.gov

Senator Robert Torricelli email: senator_torricelli@torricelli.senate.gov
United States Senate
Washington, D.C. 20510