Date:    09/18/2000  11:51 AM

Subject: S7-13-00

I am writing you regarding the SEC proposed independence rules. 
     
The SEC should allow more time for input from congress and the public before 
making a decision. Additional consideration should be given to the conclusion of
the Panel on Audit Effectiveness of the Public Oversight Board. The Panel 
concluded that "both the profession and the quality of audits are fundamentally 
sound."
     
The SEC proposal is bad news for CPAs specializing in auditing an industry. 
Public companies might 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.
     
If the rule is adopted it will have a negative effect on recruiting and 
retention of the best professionals. "Audit-only" firms will have a difficult 
time attracting professionals to a limited market. 
     
Under the SEC proposal, Audit firms will be more dependent on audit fees than 
they are today.
     
     
     
Please note new address and  telephone numbers below. 
     
Thank you,
     
Roger Barker

3121 West March Lane, Suite 100
Stockton, CA 95219-2303