Date:    09/18/2000  12:56 PM

Subject: S7-13-00

I have become aware of the proposed SEC ruling that would prohibit CPA firms 
who conduct audits for SEC clients from providing other, non-audit services 
to these clients.
     
I have read the proposal and urge you not adopt it.  Although I do not have 
any audit or SEC clients, I believe that the proposal is damaging to the CPA 
profession as a whole, and, in turn, to their clients and the general public.
     
There is no evidence that non-audit services have compromised audit quality 
or auditor independence.  A study that was conducted at the request of the 
SEC by the Panel for Audit Effectiveness of the Public Oversight Board and 
concluded that "both the profession and the quality of audits are 
fundamentally sound".  It also concluded that in numerous instances non-audit 
services contributed to a more effective audit.
     
My fear for the profession is that if this proposal is approved other 
regulatory agencies will use this as a model for their regulations.  It could 
seriously harm the way accounting firms today do business and be contrary to 
the public interest.  Restrictions on non-audit services will make firms 
overly dependent on auditing fees, which is certain to increase their costs 
to their clients.  It also could possibly degrade the accounting profession 
itself, as audit professionals will not want to work at a firm where 25% - 
40% of the market is "off-limits", and the same is true for non-audit 
professionals.  "Audit-only" firms will have difficulty in attracting and 
retaining the best and the brightest, and this could cause deterioration of 
audit quality.
     
This proposal represents a fundamental restructuring of a profession that has 
long and honorably served investors.  It seems an unnecessary and overly 
restrictive attempt by a government agency to tell a profession what service 
they may offer and to whom.  I do not want the SEC adopting rules such as this 
and I believe most Americans do not either.
     
Sincerely,
     
Beth Boyd,CPA