Date:    09/06/2000  2:55 PM

Subject: Reference File No: S7-13-00; Revision of the Commission's Au

Dear Sirs:
     
We support the Securities and Exchange Commission's ("SEC" or "Commission") 
proposed rule amendments regarding auditor independence. The proposal is a 
much-needed modernization of the auditor's rules of professional conduct as 
they relate to independence.  They will prevent the further migration of 
accounting firm's focus from audit and attest services.  
     
As a large, national consulting firm (formerly a CPA firm) comprised 
primarily of CPA's, we long ago recognized the inherent conflicts associated 
with simultaneously being an advocate and a watch dog.  We made the decision 
to forego performing attest services so as not to compromise our position as 
advocates for our clients.  The large, national accounting firms, which 
effectively control both the state and national CPA societies, will no doubt 
make many creative arguments in support of the status quo.  The simple fact 
is that these firms derive substantial revenues from non-attest services 
while giving lip service to independence.  It is not surprising that the 
quality and rigor of the audits performed by these firms has diminished.
     
We strongly support the SEC's scope of services rule and recommend that it 
be adopted as proposed.  
Sincerely, 
     
Valerie S. Bolin
     
 
     
     
     
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