September 25, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
I am writing in regards to file number S7-13-00 on the proposal to reform the rules governing auditor independence.
I am inclined to disagree with this proposal on the grounds that it will put the CPA firms and the clients as well at a great disadvantage. By passing this rule clients will be forced to engage multiple CPA's to perform the services which they are currently receiving from just one firm. This will create not only a much added expense to the clients, but also a great deal more confusion and thus inefficiency. Clients, especially when it comes to their finances, are comfortable with the familiarity of working with one CPA to cater to a majority of their needs.
As for the effect on the CPA's, the effects of this rule could be devastating to firms, especially those smaller firms which make up the majority of firms in the country. Performing non-audit services for the clients allows a CPA to become more familiar with a client and instead of hindering the CPA's independence, actually enhances the quality of the financial statements. More mistakes or irregularities will be noticed by one firm working on projects for a client than when multiple CPA's who are not in close contact are working on projects.
Overall I believe that this rule in its' present state will do more harm than good to clients and CPA's alike. I hope you will take into consideration these points and abolish the above mentioned rule. Thank you for your consideration on this matter.
Samantha Rudder, CPA Candidate