Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Re: Proposed Rule Regarding Revision of the Commission's Auditor Independence Requirements - Summary of Intended Testimony September 20 (Comment File No. S7-13-00)

I am Chief Operating Officer of myCFO, Inc., a professional services company that combines a web enabled, state of the art, online technology with best in class professional advisors to bring a total solution to the financial lives of individuals. I am a CPA and have an MBA.

I started my professional career with Deloitte Haskins and Sells in 1978, and was admitted to the same firm as a Partner in 1986. I held various client service and management positions with Deloitte until my resignation on October 31, 1999. I was a member of Deloitte's Board of Directors, and Deloitte's Management Committee. My last position with Deloitte & Touche was Regional Managing Partner, West Region. In this position I had direct responsibility for all Deloitte services in Accounting and Auditing, Tax, and Management Solutions and Consulting for all of Deloitte's West coast offices (Los Angeles, San Francisco, Seattle, Orange County, San Jose, Portland, San Diego, Hawaii, Las Vegas and Reno). Many of the leading US new economy companies are in this region.

The purpose of my testimony is to describe the business advice paradigm I believe is needed for immature, new economy businesses. "Trusted business advisor" is an oft-used term to describe a professional in whom a client has complete faith that such advisor is looking after the client's needs and recommending the best solutions for the client, while at the same time adhering to the highest standards of professional ethics. For new economy companies the luxury of having one or two firms that can provide most of the advisory services needed to be successful is a most important need, so the companies' management can focus on building and running the business rather than managing professional service firm relationships. The added comfort that such advisor may also be the trusted auditor is an aspect that I view as a positive, not a conflict. I anticipate further discussing my views on these points on September 20 in Washington.


Frank Tirelli