Subject: Reference file No.:  S7-13-00

Date:    08/15/2000 5:02 PM
     
     
To: Johnathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
     
Dear Mr. Katz:
     
I am writing in oposition to the new proposed rule prohibiting accounting 
firms from performing non-audit services for SEC regestered audit clients.  
     
I am a CPA working in the banking industry as a Chief Financial Officer. 
The bank where I am employed is not regestered with the SEC, however I
believe that your proposed rule would negatively affect the banking industry 
a great deal.  It is my understanding that the OCC and other bank regulators 
have already taken up the mantle of your proposed new rule, and are ready to 
implement it, maybe even on non-SEC regestered banks.  This would create 
undue hardship and expense for us as an independent community bank.  
     
The banking industry depends on the expertise, professionalism, and 
independence of CPA firms to not only provide audit services, but to provide 
other non-audit services.  I estimate that the new rule would increase costs 
to the bank by 20% to 30% of current fees.  This is due to the duplication of 
work that would have to be done by auditors if they were not performing the 
non-audit services.  
     
As you know, the accounting profession holds the highest standard of perhaps 
any profession on quality, independence, and ethics.  
     
In addition to the above comments, I am opposed to the new ruling for the 
following reasons:
 1.  There is no evidence or facts presented by the SEC that the proposed
ruling is needed or warrented due to any breach of duty or failure of the 
existing standards. 
2.  The SEC should accept the findings of the Panel on Audit Effectiveness 
of the Public Oversight Board that was formed at the SEC's request to make a 
recommendation.  They found that there was no evidence of a need for the 
proposed rule.  
     
There are many other reasons that I oppose the proposed ruling, but quite 
frankly, I have a bank to operate.  It's obsurd that I have to take 
productive time to write this letter to try to halt unproductive and 
burdensome new rules and regulations.  
     
I plan to send a copy of this letter to my legislators.  
     
Thank you for considering my views.
     
Robert Berryhill, Executive Vice President and Cashier 
First National Bank of Bastrop
P. O. Drawer F
Bastrop, Texas  78602