Subject: File No. S7-13-00: Revision of the Commission's Auditor
	In
Author:  "Anil K. Thomas" 
Date:    10/03/2000 12:40 PM
     
     
     
     
Chairman, I apologize for sending this comment directly to you.  However, 
because the comment period has elapsed, and I thought this comment was 
important, I wanted to be certain that it reached you.  Regarding the above 
proposal, if not prohibition, there must be at least disclosure.  I would 
suggest the following:
     
Any fees paid to an auditor for non-audit services must be disclosed in the 
footnotes.  I envision something like this:
     
The auditor has performed the following services for ABC Corporation for the 
year ended XX/YY/ZZ:
     Audit servces       $___________
     Consulting services $___________
     Bookkeeping services     $___________ 
     Tax services        $___________
     
This information would allow readers to judge for themselves if independence has
been compromised.  Whether or not there are actual proven cases of non-audit 
work influencing audit results, there is certainly sufficient doubt to warrant 
such disclosure.
     
Notes:
1. In addition to the nonaudit fees, the audit fees must also be disclosed, so 
the relative value of the audit engagement can be judged.
2. The disclosure might be made as part of the "Related Parties" footnote. 
3. If not in the published report, it can at least be required in the SEC 
filings (such as the 8k).