Date:    09/19/2000  6:40 PM

Subject: SEC and Auditor Independence

As a member of the CPA profession for over 25 years and as the managing partner 
of a 30+ person firm I feel obligated to take issue with your proposed rule 
governing auditor independence that would limit services to clients. There is no
objective evidence to support this position and it would likely result in 
significant cost increases and/or a deterioration of the quantity and quality of
services provided. The trickle down to non-SEC registrants is inevitable.
     
Let's let the current rules, audit committees and the free market system drive 
the decision on the use of service providers. There is no benefit to business or
consumers in your proposal.
     
Sincerely,
     
Thomas M. Gilbert, CPA
Gilbert Accountancy Corporation