From: Sarah Adams 

Sent: Wednesday, August 30, 2000 5:21 PM 
Subject: Reference File No: S7-13-00
     
     
Our firm would like to provide comments to the current pending action to limit 
the scope of CPA services.  We are a small, growing CPA firm with only 2 CPAs 
and a staff of 4.  We are not currently engaged to perform audits of any 
publicly trading companies, but would like to offer comments as our services 
could possibly change in the future.
     
(1) The SEC was wise to form a panel to evaluate the audit effectiveness of the 
Public as an oversight board, and we are sure this Panel thoroughly reviewed the
facts and circumstances, as you would expect any CPA firm to do in the course of
an audit.  It is our understanding the Panel could find no evidence that the 
provision of non-audit services has hurt audit quality.  In fact, we understand 
it concluded on numerous instances that non-audit services contributed to a more
effective audit.  We also would agree with that conclusion.  This is not to say 
that independence is not of the utmost necessity in providing assurance in an 
audit.  
     
(2) We feel that the CPA community as a whole has been "watered-down" somewhat 
by the allowance of non-CPA owners and members.  CPA's have always been held to 
the highest standard of quality, which is expected in each firm.  But the 
inclusion of others in firms that are non-CPAs who may or may not be held to 
these standards of quality, we feel, have resulted in some "appearance" of 
lesser standards, whether this is reality or not.  We feel this issue has 
brought about most of the concerns the SEC is expressing.  
     
(3) Again, independence is a serious issue.  But limiting the types of services 
that are a real benefit to our clients is not in the best interest of the 
business community as a whole.  Because CPAs have excellent business knowledge, 
and most excellent computer knowledge, it is the CPA that most companies look to
to provide these integrated services.  There are relatively few other 
professions that can provide this level of professionalism covering such a broad
array of services.
     
We urge you to evaluate what your own Panel's results were.  If independence is 
still a concern, please look to other ways to establish controls rather than 
limiting valuable services provided by CPAs.
     
Yours truly,
     
Sarah A. Adams, CPA
E. Robert Adams, Jr., CPA