Date:    09/20/2000  9:57 AM

Subject: S7-13-00

I am writing to let you know that I strongly oppose the change in scope of 
services rule for CPAs and accounting firms. Please let me explain why:
     
*       The proposed rule severely restricts services offered by accounting 
firms which is going to fundamentally restructure the profession that has 
successfully given investors the reliable, independent data that they need 
for the past century
*       The SEC has based its decision to move forward with this rule 
without facts or evidence. Even the SEC admits that there is no empirical 
evidence that non-audit services have compromised audit quality or auditor 
independence, nor ever caused an audit failure.
*       If your ruling passes, it sets a dangerous precedent which may 
result in other regulators adopting the same rules.
     
I am a CPA in the credit union industry. I am the President and CEO of a 
$200 million credit union that relies on using an accounting firm which 
specializes in credit union services. The firm provides our annual audit as 
well as consultative services through out the year. I view them as an 
independent, non-biased expert which comes to our credit union to not only 
audit our records but also to provide me invaluable services such as 
internal audit reviews, recruitment services for senior management and 
workshops for our accounting staff. If your rule passes, it is likely that 
the banking and credit union regulators will adopt similar rules. This would 
drastically affect our business by changing our relationship with our CPA 
expert.
     
Your proposed rule must be stopped. CPAs and accounting firms pride 
themselves on being an ethical business partner with its clients. Please 
don't try to "fix" something that is not broken.
     
Sincerely,
     
Carrie Birkhofer
President and CEO
Bay Federal Credit Union
3333 Clares Street
Capitola, CA 95010