Author:  "Tom Bayer" 
Date:    11/04/2000  8:32 PM

To the following Commissioners:
     
Chairman Arthur Levitt 
Commissioner Paul R. Casey 
Commissioner Isaac C. Hunt, Jr. 
Commissioner Laura S. Unger 
     
From:  Tom Bayer, CPA at Sikich Gardner & Co, LLP, Springfield, Illinois
     
Honorable Commissioners:
     
I have read with great interest the developments of auditor independence issues 
raised by the SEC.  I do believe that we all must work together to protect the 
public interest, as stated by Chairman Levitt in his recent speech to the AICPA 
in Las Vegas.  That has to be the most important issue our firms must embrace 
and uphold.   My greatest concern is that these initiatives will trickle down to
the smaller practitioner and our practice will be dismantled in order to comply.
     
     
How to ensure that public interest is being protected comes down to the 
integrity of each and every CPA practicing out there.  We as a profession must 
adopt self regulatory tools which will be monitored through our peer review 
process.  Our profession is changing so rapidly that its conceivable that there 
is a perceived problem in our self regulatory tools.  However, I can tell you 
that we take independence very seriously at our firm.  By the way, we do NO SEC 
work.  However, the professional standards are paramount in our firm.  We work 
very diligently to ensure that we comply with those standards.  
     
I hope that the leadership of the AICPA can develop some solutions to the issues
you raise so we can move away from the negativity this has created.  
     
I would like to make just a couple of specific points and I will leave you with 
those thoughts:
     
1.  Please understand that the variety of consulting services add so much value 
to our ability to audit that by taking those services away from us as auditors 
would weaken the audit quality.
     
2.  Please also understand that ever since competitive bidding began for audit 
services, our services became a commodity.  I sense a passion for uplifting and 
maintaining the independence and integrity of audits.  This is one issue which 
has to be addressed.  There are pricing pressures for these services - there is 
more revenue and more value in the other consulting services.
     
3.  I would invite the SEC in as regulator in our peer review process.  I think 
sometimes there is a perception of the "fox watching the chicken coop".
     
4.  I think full disclosure of all client relationships should be a part of the 
self-regulatory process.  I think the issue of independence should become a 
bigger issue in our process, to ensure that we as a profession are upholding the
standards.
     
5.  To some extent, LLPs and LLCs have diluted the risk a firm as a whole takes 
in their auditing practice.  I think we should have some way of putting 
additional "peer pressure" on CPAs working in the same firm to ensure rules are 
not being broken.
     
In the event there is a "trickle down" of these regulations as they are 
currently being proposed, and, we as a firm essentially dismantle, it could have
a dramatic effect on my life and my career.  I am sure there are thousands of 
others just like me.  Please take great care in your decision making process.