Date:    08/23/2000  5:25 PM
Subject: S7-13-00

I am a C.P.A. in industry, having been so for over 20 years.  I am opposed 
to implementation of the subject rule as it is currently written for the 
following reasons:
     
Of the 10 non-audit services listed, only the performance of management 
functions or human resource functions would, per se, compromise an auditors 
independence.  The other functions mentioned do not, and would be overly 
restrictive to the many other functions that independent CPA's have 
traditionally provided their clients for years.  Because of their 
familiarity with the client's business, it makes sense for CPA's to be 
involved in these activities.  In particular, the definition of any 
"affiliate" of the accounting firm is so overly restrictive that it borders 
on the ridiculous.  In addition, the SEC's definition of other services is 
too broad and would result in confusion over activities that are permitted 
and those that are not.
     
Please go back to the drawing board on this one and start over. 
     
     
David W. Amend 
Executive Vice-President 
     
WorkPlaceUSA
214 696-6900, x104 (Dallas)  817 339-1126 (Ft. Worth) 
214 696-0037 fax
     
david.amend@wpcompanies.com
www.wp-usa.com