September 21, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
When our firm learned of the proposed rule the SEC is championing regarding the regulation of CPA practices, we were stunned and extremely disturbed. The proposed rule seems to be moving forward without a solid foundation in fact or evidence that this type of regulation is necessary, and with little regard to the sweeping negative impact it would have on accounting practices such as ours.
Mueller & Co., LLP has spent the last thirty-two years building a highly respected, successful practice by providing it's clients, which include both businesses and individuals, with a full line of financial services to serve all their specific needs. Along with traditional accounting services such as audit, tax and controllership services we also offer management consulting, financial software selection, implementation and training, investment advise and management, estate and retirement planning, litigation support, mortgage services.
The rule being proposed by the SEC would obviously have a dramatic impact on the future growth and opportunities available to our firm as well as the ability for us to provide all the services our clients have come to rely upon. The proposed rule would force our clients to hire additional accounting professionals so they may receive the broad range of ancillary services required to fulfill their needs. Additionally, this rule would drastically hinder any accounting firms ability to gain new clients through business associations and referral sources. By limiting the establishment of joint ventures and commercially valuable business relationships the accounting profession as a whole will be needlessly restricted from expanding into new markets.
We urge you to take more time, conduct a comprehensive investigation to determine if a need truly exists for this type of regulation and seriously consider the broad impact this rule could have on the accounting profession specifically and businesses in general.
Your prompt and thorough attention to our concerns is greatly appreciated.
Mueller & Co., LLP
1750 Grandstand Place
Elgin, IL 60123