Date:    08/28/2000  4:09 PM

Subject: File S7-13-00

I am encouraged by representatives of my profession to oppose the above 
rule regarding the impact of consulting services on the independence of 
auditors.  
     
I am in favor of the rule, notwithstanding my profession's opposition.  
     
Just as CPA Firms hire other CPA firms to peer review their own 
procedures or audit their own financial statements, they should 
encourage their audit clients to engage other consultants to design and 
implement internal procedures affecting the integrity of the client's 
financial information.  It will then be the auditors function to 
independently test the reliance of such procedures when designed or when 
implemented.
     
There have been adequately documented cases in recent years (and in not 
so recent years) of national accounting firms ignoring the rules of our 
profession.  Consultants who are not trained to follow our rules of 
conduct should not be associated with their clients' auditors.  
     
Our profession has no function in an industrial economy that is not 
totally dependent on our collective reputation for integrity.  I have no 
doubt that over time, real independence problems will arise from 
consulting services rendered by auditor firms, and those problems will 
erode the public's confidence in us all.  
     
I've worked too hard to earn my Firm's reputation for honesty, 
integrity, and ability to have that reputation soiled by someone else's 
avarice.
     
Robert O. Beck III
CPA - NC - #8926
4500 Cameron Valley Pkwy
Suite 130
Charlotte, NC 28211-3552