Date: 09/25/2000 11:32 AM Subject: File No. S7-13-00 I support the proposed rules on auditor independence. It seems to me that auditor independence is jeopardized any time the fees from any client make up a significant portion of the billings attributable to the partner in charge of the engagement, that partner is not free from client pressure. If the fees from one client make up only 1% of a partner's total billing, that partner can probably afford to lose that client and will treat the engagement with an independent mental attitude. On the other hand, if the fees from a client make up 90% a partner's total billings, that partner may be less independent than employees of the client. After all, a company cannot easily fire employees; the firing has to be justified and the employee may sue the company. I have never heard of a CPA suing a former client because of losing an engagement, and it seems to me to be an easy matter for a company to switch auditors. I realize that restricting non-audit services will not guarantee the independence of auditors, but it should help to reduce some of the pressure on the partner in charge of the audit to see everything the way client management sees it. I also realize there is considerable opposition to some of the proposed rules. Maybe an alternative should be considered; whenever non-audit services are performed for an audit client, the CPA firm should be required to disclose to the SEC something like the following: "All fees paid by XYZ client equal __% of the total billings attributable to the partner in charge of the audit." I commend the efforts of the SEC to address the critical issue of auditor independence. John Corless, PhD, CPA, CIA Professor of Accountancy CSU-Sacramento 6000 J St. Sacramento, CA 95819-6088