Subject: S7-13-00  Auditor Independence

Date:    07/31/2000 7:56 AM
     
     
To:  Securities and Exchange Commission 
From:  David W. Underwood, CFO
        Curries Company
        PO Box 1648
        Mason City, IA  50402-1648
     
RE:     S7-13-00  Auditor Independence
     
I am writing in opposition to the your proposed S7-13-00 rule regarding 
auditor independence and the scope of services a CPA firm could offer to 
Audit Clients.  
     
My background is as a CPA, including a partner in a major firm.  Currently I 
am the CFO of several companies that are owned by a larger, publicly traded 
company.  I am also a stockholder in many publicly traded companies.
     
The two major reasons that I oppose your proposed regulation are:
        The potential for this regulation in limiting tax services to return
preparation by the firm doing our audit.  We do not have a professional tax 
staff available to fully represent our operations before the IRS and state 
revenue departments.  We rely on the auditing firm to prepare our returns 
and to represent us across the country in the various jurisdictions we 
operate.  If there were to be any limitations on the auditors ability to 
represent us, I would estimate that our costs of tax compliance will 
significantly increase.  I see no value added to the shareholders of the 
company by such a limitation.
     
        I am also disturbed by the limitation of management's freedom of
choice when seeking outside consulting services.  We don't always chose the 
firm that does our audit.  We always chose the firm that we believe can add 
the most value to the engagement.  Whether these services are related to our 
processes and procedures or to an acquisition, we believe that management 
should have the freedom to chose the professional firms that can best 
provide the required services.  
     
The ultimate decisions reside with management, the Board of Directors, and 
the Audit Committee.  Your rule will burden public companies with higher 
costs, wasted efforts and confusion.  I question your authority to 
"regulate" the accounting profession.  Where are you headed next?  The legal 
profession?  I believe you are seeing ghosts where there are none.  
     
Please rethink your position.
     
Respectfully submitted,
David W. Underwood