Author:  "Russ Wilson" 
Date:    09/06/2000  3:03 PM

Subject: S7-13-00

In regard to your proposed rule prohibiting non-audit services to CPA firm 
attest clients, I would like to express my dissatisfaction with both your 
process and the proposed outcome.  
     
The SEC has proposed these rules with basically no evidence whatsoever 
suggesting that non-audit services have ever compromised audit quality, auditor 
independence, or caused an audit failure.  It is my understanding that none of 
the reports or studies cited by the SEC has concluded that the scope of services
impaired audit effectiveness, or that an exclusionary ban was necessary or 
appropriate.  I simply cannot fathom your outcome given the data you had to work
with.  Therefore I can only conclude that it is someone's political agenda that 
is driving this process, not any kind of rational rule-making.  It appears to be
a rush to regulate, period!  It ignores your own processes (i.e. the work of the
ISB to develop a conceptual framework), is on a timetable that simply does not 
allow for any alternative proposals to be formulated, has not given appropriate 
consideration to reforms already in the works, etc., etc.  
     
Meanwhile, I can foresee the enormous turmoil this type of rule making will have
on my profession, and the unfortunate negative impact on our small SEC reporting
clients that require considerable hand-holding to comply with SEC reporting 
rules.  I fail to see how the investing public benefits in any way from this 
proposal.