August 29, 2000

Mr. Richard Miller, General Counsel
1211 Avenue of the Americas
New York, NY 10036-8775

RE: SEC Proposal

Dear Mr. Miller:

As you know the environment in which we currently operate has significantly changed. The role of the accountant has transformed from traditional attest and tax services to that of a business advisor. We are looked upon to assist a client in "where they are going" and not just report on "where they've been". Our training puts us in a unique position to be able to analyze data and systems and make recommendations on "how things can be done better" to make a company more profitable and less susceptible to errors and irregularities.

I am the Managing Partner of a local firm with 7 professional staff and 9 total staff. Our attest clients are principally small not-for-profit agencies. As you know, not-for-profits with their limited budgets find it even harder than their for-profit counterparts to be able to hire adequate staff or find and retain consultants with the appropriate financial expertise to help them. Traditionally, they turn to their auditors to provide the additional financial services they need throughout the year such as:

Obviously we no not step over the boundary in these engagements and in any way take on the role of management. However, we are very instrumental in helping management reach the goals of the agency and assist management in creating a more competitive agency. Such services also allow these agencies to expand their services to their constituents.

We, unlike many other small firms, have built our practice in the areas of audit and consulting, whereby these two aspects of our practice comprise about 60% of our billing. Audit services have never been a huge money maker for us, however they provide an in-road into the consulting services. In addition, we find that many of our clients want to work with one firm, rather than several.

If provisions were implemented to curtail our firms ability to perform all these services for our clients, we would experience approximately a 20-25% decrease in our annual billings. This means jobs, both professional and administrative. How are small firms expected to survive?


Kenneth Cerini

Kenneth Cerini, CPA, CFP