Date:    09/18/2000  12:15 PM

Subject: File No. S7-13-00 Revision of the Commission

Dear Mr. Katz:
     
I want to offer my support for the changes the Commission is proposing for 
auditor independence.  I commend you and your committee for this initiative 
aimed at improving and modernizing the public accounting profession.
     
Having been both in internal audit management, controllership and public 
accounting roles, independence has always been a topic that I have had 
great interest in.  I also spent time defending our internal audit 
department against the aggressive sale by our Big 5 auditors.  This alone 
has given me great perspective of the seriousness of this issue.  I have 
also learned that perception is often times as important as reality.  The 
work done by public accountants must be both independent and perceived by 
investors and others in the public arena as independent.   Anything that 
compromises that position should not be tolerated as our financial markets, 
indeed our entire business community, rely totally on this position to 
function.
     
I reviewed the proposed rule amendments and also the hearing testimony from 
the hearing held July 26, 2000.  Like many of those providing testimony, I 
believe auditor independence will be best achieved by curbing the 
proliferation of non-audit services provided by a public accounting firm to 
its audit clients.  I think an outright ban on these non-audit services is 
the only way to guarantee compliance.  There are plenty of non-audit clients 
that audit firms can pursue to provide their non-audit services.
At a minimum, the proposed proxy disclosure requirements will help the 
public understand the relationship an entity has with its public accounting 
firm.
     
There are many non-audit services that could, potentially, impair 
independence.  Certainly any outsourcing of the internal audit function to 
the organization's external auditing firm impairs independence.  But we must 
also look deeper and review the services that are not so obvious in their 
ability to impair independence.  Services such as financial information 
systems design and implementation, appraisal or valuation services, 
actuarial services, human resources and many management functions must also 
be reviewed.  I have always believed that auditors cannot function as a part 
of client management and remain independent.  It is human nature, especially 
when fees are involved.
     
Now is the time to strengthen and modernize our profession and the proposed 
SEC rule amendments regarding auditor independence do just that.  I urge you 
to go forward with these needed changes including the relaxing of 
restrictions on investment and employment imputed to a public accounting 
firm.
     
Thank you and all the Commissioners, I look forward to working under the 
new guidelines.
     
Sincerely,
     
Monte F. Weirman, CPA