Date:    08/22/2000  1:05 PM

Subject: S7-13-00

I am  writing in opposition to the proposed SEC rule prohibiting non-audit 
services to CPA firms' attest clients.  My firm serves many  smaller SEC 
registrants.  Many of these companies do not have sufficient in-house staffing 
to comply with SEC reporting rules and rely on outside CPA firms for assistance.
They rely on their CPA firms to perform not only for their annual audit but to 
also advise them on the many systems, practices and policies for a successful 
business and regulatory compliance. The  rule proposed by the SEC will 
effectively eliminate our ability to provide this service which benefits the 
investing public, the SEC, and the client.
     
The SEC proposal appears to be based upon conjecture rather than evidence  that 
the prohibited services compromise independence. The proposal will adversely 
affect both large and small CPA firms providing services to SEC registrants and 
will significantly diminish firms' abilities to attract and retain non-CPA 
specialists necessary in today's technological environment.  Ultimately, audit 
quality and the investing public will suffer.  
     
Regards,
     
Paul S. Farkas