Date: 09/19/2000 11:52 AM Subject: Re: Proposed ruling concerning CPA's independence #S7-13-00 Jonathan G. Katz, Secretary, SEC Dear Mr. Katz: Re: Proposed ruling concerning CPA's independence. I am a partner in a local CPA firm with 13 associates in Woodinville, Washington. Our firm has been practicing since 1978 and we serve primarily small businesses and their owners. Our firm as well as CPA firms much larger than ours, are actively involved in what the CPA profession calls "other accounting services" with many of our clients. These accounting assistance services are performed to help our clients generate an adjusted trial balance. Our compilation and review services begin once the client has an adjusted trial balance. Without bookkeeping assistance or "other accounting services", many of our clients would not be able to annually close their books or generate accurate trial balances from which financial statements could be prepared. For this reason I am opposed to the proposed SEC rule as described in File #S7-13-00. I am aware that the proposed ruling is not necessarily aimed at the small business community which relies so heavily on accounting assistance from their CPA's. However, I am opposed to the proposed ruling for all size companies, whether private or public. CPA firm internal controls and independent partner review of significant "accounting" services performed for audit, review or compilation clients should be sufficient safeguards for the public and investors to preclude this proposed ruling. Thank you for your consideration. Sincerely, Christopher J. Rieke, CPA