Date:    08/22/2000  11:06 AM

Subject: S7-13-00 

I am in total support of the SEC proposed rules changes regarding 
consulting for audit clients. The only negative that I see is that it 
does not go far enough.
     
As a CPA and a member of the AICPA, I take issue with the AICPA stance 
on these issues as they are simply parroting the views of the big 5 
firms.
     
I worked for two of the then big 8, firms and I have seen them 
prostitute themselves many times for audit fees (these were the days 
when consulting was in its infancy). Once for as little as $15,000 in 
audit fees. I can only imagine what they would do when millions of 
dollars of audit and consulting fees are at stake. INDEPENDENCE at this 
level is an oxymoron. Audit firms of public companies should not, in my 
opinion, be allowed to perform any consulting work for their public 
company clients.
     
Doesn't this also fly in the face of a recent peer review ruling, that 
the AICPA made, which prohibits a reviewer from performing pre issuance 
engagement reviews for a review client? While I totally agree with this 
ruling, I can not reconcile it to the current stand on consulting by the 
big 5 on their publicly held audit clients!
     
Sincerely,
     
William V. Allen, Jr., CPA