Date:    08/26/2000  2:30 PM

Subject: Proposed rule governing auditor independence

I have read the material furnished by the AICPA concerning the proposed rule 
governing auditor independence.  Of course, the material is not supportive of 
the new rule.  However, I have some supportive comments that may be of interest.
     
First, I will provide some information about my background and experience.  For 
over 25 years I practiced accounting and eventually became an audit partner with
Arthur Young.  For the past 18 years or so, I have been CEO of a couple of 
operating companies and now have my own investment advisory firm.  I am a 
registered investment advisor with the SEC and work on a fee only basis for high
net worth individuals.  When in the practice of public accounting several years,
I worked on several firm on firm peer reviews as well as in-house reviews. 
Currently, I am a member of the Oklahoma State Society of CPA's committee on 
professional ethics.  
     
After reading the information provided on the proposed independence rule, I felt
compelled to provide my thoughts and comments.  I support the new rule as 
proposed.  It gets right to the core of independence by eliminating the source 
of potential conflicts.  I understand the opposition by the major accounting 
firms and the AICPA because they are in the process of expanding the CPA's scope
of services and the proposed rule would limit the scope of services in the 
interest of independence.  My experience as an audit partner and peer review 
participant would support the limitation on scope of services.  I observed 
numerous instances where services other than the attest function became an 
obstacle to independence.  The attest function should be performed by auditors 
who have no conflicts of interest or appearance of conflicts.  This means that 
other services should not be provided attest function clients.  I know that is 
not a popular position by the profession, but it is a necessary one to protect 
the integrity of the auditor's opinion.  Our free market and our economic system
only work as well as they do because of reliable transparency.  In the work I 
perform today it is paramount that I am able to receive current, reliable 
information.  If that information has been attested to, I must be able to rely 
on the attestation without doubt.  Having auditors who are collecting revenue 
for other than audit services from audit clients taints the reliability of the 
audit opinion and limits the usefulness of the information.
     
I strongly encourage you to adopt this rule on independence.  I firmly believe 
that you will see positive results and fewer audit failures.  The stockholders 
and users of the attested financial information will be the beneficiaries as 
well as those engaged in the capital formation industry.
     
Jerry W. Plant, CFA, CPA.