Date:    09/14/2000  1:16 PM

Subject: S7-13-00

This is in response to the proposed rule by the SEC regarding non-audit services
by CPA firms to their audit clients.  As a CPA in a regional accounting firm, I 
have been watching and listening with great interest as the SEC beats the drum 
of the non-audit services prohibition.  The assertion is that the attest 
function is compromised by the non-attest services provided by the CPA firm.  
     
To my knowledge, there has been no occurrence where an audit failure has been 
linked to the providing of non-audit services by CPA firms who performed the 
audit.  The non-attest services that are provided by CPA's do, in fact, help to 
make company's procedures, policies, and operations stronger.   CPA's have 
served public companies and shareholders by effectively functioning in both the 
attest and the non-attest areas for over a century.  The SEC is intimating that 
we have a situation where the fox is guarding the henhouse.  That is simply not 
the case.
     
If a rule such as this is passed, the logical conclusion is that there will be 
fewer service providers from which public companies can choose.  Oftentimes, 
with the intimate knowledge that the CPA firm has of its clients, they are the 
best choice for providing these necessary services.   In the complex world in 
which we live and operate, it is absolutely essential that businesses have 
access to the best services possible to help them solve problems and fulfill the
needs of the company and shareholders.  Let the free market determine who is 
best qualified to deliver the services required by publicly traded companies.
     
Is this problem so pervasive that it must be dealt with by use of a sledgehammer
type approach?
     
Yours very truly,
     
     
Michael E. Lynch