Date:    09/20/2000  11:00 AM

Subject: File #S7-13-00
 
I would like to express my deep concern regarding the proposed rule changes 
initiated by the Securities and Exchange Commission (SEC).
     
If the rule is approved as currently proposed, accounting firms performing 
audits for SEC registrants, and perhaps non-public clients, might ultimately 
be prohibited from providing any audit client with most non-audit services. 
This restructuring of the accounting profession would seriously impair our 
firms ability to perform services to our current clients, and will severely 
limit our future clients.  I feel this proposal has far reaching 
implications, with profound consequences for the future of the accounting 
profession and would adversely affect all accounting firms and companies, 
public and private.
     
The SEC has decided to move forward with this proposal without any evidence 
or facts that non-audit services have compromised audit quality or auditor 
independence, nor ever caused an audit failure.  The Panel on Audit 
Effectiveness of the Public Oversight Board, formed at the request of the 
SEC, concluded that both the profession and the quality of audits are 
fundamentally sound.  The panel could find no evidence of non-audit services 
hurting audit quality.  The panel in fact concluded that in most cases, 
non-audit services contributed to a more effective audit.  Placing these 
restrictions on audit clients and CPAs could have an adverse effect on the 
quality of an audit.
     
For CPAs working in industry, this is not good news because it would 
restrict public companies' freedom of choice when seeking outside 
professional services.   This proposal would force public companies to 
choose a firm solely for its auditing abilities or as a provider of other 
services.  Also, public companies would be compelled to dismiss an audit 
firm that has done consistently outstanding work in order to obtain services 
from the auditor's non-audit colleagues.
     
Even though the proposal "would not affect tax-related services" to audit 
clients, it would ban acting as an advocate for an audit client, or 
providing expert services in 
     
administrative proceedings, thus potentially prohibiting CPAs from 
representing audit clients before the IRS.
     
The most dangerous aspect of this proposal is this rule would set a 
precedent for other regulators to follow.  This new rule would be the model 
on state boards of accountancy as well as federal (e.g., banking and ERISA) 
and other regulators.  This could also influence the regulatory approach to 
auditor independence outside the United States.
     
There would be a negative effect on recruiting and retaining top 
professionals.  The best and brightest students will not be drawn to a firm 
with limited opportunities.  This fact alone will seriously impair the 
growth of the overall accounting profession.  Students realizing the 
limitations could possibly seek other industries with broader career 
opportunities.
     
Ahlbeck & Company, a well-established accounting firm continues to broaden 
our client base in the Chicago area and beyond as we focus on responding to 
the needs of our clients.  Our clients vary in size from sole entrepreneurs 
to large corporations, and our industry base ranges from non-profits and 
tax-exempt organizations to wholesalers, retailers and professional service 
firms.  This proposal would seriously handicap the services we currently 
offer our clients, and in effect, would do considerable damage to our 
current client base.  We pride ourselves on the variety of services we offer 
our clients and we are dedicated to provide exceptional personalized client 
service in response to their individual needs.  
     
We have dedicated a great deal of time and effort in attracting and 
retaining top employees in the accounting field.  This proposal would cause 
some of our best employees to seek employment elsewhere if they are 
restricted in services we provide. 
     
Thank you for the opportunity to share my concerns.
     
Very truly yours,
     
*       Dirk
     
     
AHLBECK & COMPANY
     
CERTIFIED       1665 ELK BOULEVARD      
PUBLIC  DES PLAINES, ILLINOIS   
ACCOUNTANTS     60016-4798      
 
     
DIRK T. AHLBECK