Date:    09/20/2000  3:32 PM

Subject: Reference File No.:  S7-13-00

Importance: High
I am writing to express my concern for the SEC proposal, referenced above, 
regarding Non-audit Services. 
I am a CPA working for a medium-sized public accounting firm, and am 
concerned that the proposed rules would dramatically curtail the ability of 
accounting firms to provide services other than audit and tax services to 
SEC clients. 
If adopted,this rules could eventually restrict our ability to provide 
accounting and bookkeeping services, valuations, management, consulting, 
financial planning, and other services that are the growing areas of service 
for most local firms. Local CPA firms will find difficulty surviving if they 
are forced to choose between audit and non-audit services!
None of the research conducted by the SEC has found evidence to support the 
conclusion that providing non-audit services has impaired independence or 
audit quality. CPAs take the profession's independence standards and the 
responsibility to represent the public interest seriously. It's an attribute 
and responsibility that defines us as a profession. Since there has been 
nothing to demonstrate any significant problem in this regard, we struggle 
to figure out just what is the motivation to pursue such a dramatic change! 
I was also concerned when I read that the SEC ignored the conclusion of the 
current Panel on Audit Effectiveness of the Public Oversight Board, a Panel 
that was formed at the request of the SEC. The panel concluded that, "both 
the profession and the quality of audits are fundamentally sound." The Panel 
said it could find no evidence that the provision of non-audit services has 
hurt audit quality. On the contrary, it concluded that in numerous instances 
non-audit services contributed to a more effective audit. 
In addition, the SEC lacks authority for its sweeping scope of services rule. 
The statutory provisions cited by the SEC in the proposed rule pertain to 
public companies' filing of financial statements that have been audited by 
independent accountants and do not expressly authorize the SEC to make rules 
governing or regulating directly the accounting profession itself. The 
proposed rule is based primarily, if not entirely, on alleged concerns 
relating to the "appearance of independence" - but not independence in fact. 
The SEC does not have statutory authority to impose restrictions because of 
possible perceptions about independence. 
In closing, I feel that the SEC proposal is unwarranted and without merit. 
Please consider the facts stated in this letter when making your decisions. 
I am also urging our congressional representatives and Senators to support 
us in opposing the SEC's apparent plans for adoption.
Thank you for your time and consideration. 
Sincerely,
Sharon Mackey