Date:    08/29/2000  11:44 AM

Subject: S7-13-00
s 
This e-mail is intended to give feedback on the proposed SEC rule which would 
prohibit non-audit services to a CPA firm's attest clients.  I oppose these 
rules for two primary reasons:
     
1.  Increased cost.  Our firm audits several smaller SEC registrants.  These are
smaller companies that are financially struggling to comply with the cost of the
current SEC filing requirements.  There is no doubt that requiring these 
companies to use another CPA firm to service their non-audit needs will increase
their costs.  We provide these services as part of an integrated, cost-effective
relationship.  The SEC will need to justify to the investing public why the 
added cost is justified when there has been no empirical data to support the 
assumption independence has been compromised under current relationships.
     
2.  Increased risk to the investing public.  I suggest the SEC consider the 
value to a company in having an intergrated service approach.  The ultimate goal
of the SEC should be protect the investing public from erroneous or misleading 
information.  By limiting the knowledge of the auditing CPA firm, you are 
creating an environment where it is more likely that erroneous or misleading 
information will be released.  An effective auditor is an informed auditor.  If 
the non-audit services are hidden from the auditor, you are placing an 
increasing burden on the auditor and the company to make sure all relevant 
information is disclosed.  By being involved in the non-audit services, the 
auditor is aware of all the company's issues.
     
I strongly oppose these propose rules, both as a practioner and as part of the 
investing public.
     
Sincerely, 
     
Dick Fohn, CPA