Subject: SEC Proposal Limiting Scope of CPA Services

Date:    07/31/2000 4:42 PM
     
     
     
To: rule-comments@sec.gov
     
From:   W. Thomas Brooks
     
Re: Reference File No.  S7-13-00
     
Subject:    SEC Proposal Limiting Scope of CPA Services
     
    My firm does not currently audit SEC clients, but I feel it is only a 
matter of time before the same proposal will affect smaller firms.
     
    Our American and Florida Institute of Certified Public Accountants have 
done an outstanding job of regulating our profession.  As accountants, we are 
consistently rated at the top of public confidence surveys.  They have been 
diligent in regulating and the oversight of our profession to maintain the 
confidence level of the public.
     
    It is with those comments that I suggest your strong consideration of the 
input of these two outstanding organizations.  
     
    It is only in recent years that the public has recognized that 
accountants in many cases are their best consultants as well as tax return 
preparers and auditors.
     
    An integral part of any audit is internal control and systems review.  It 
is efficient and cost saving for the client to have their accountants perform 
additional services where applicable avoiding duplication of efforts if 
someone new were to start over.  The proposal does not allow a client to 
choose who they wish to perform the services.
     
    It is an exciting world we live in today, and the demand for new 
professionals is greater than the supply.  Restricting the services will make 
it more difficult to recruit the next generation if they are told their quest 
for expansion of knowledge in different areas is restricted.
     
    One of the greatest frustration of our clients is the necessity to hire 
so many different professionals or consultants to get the job done with no 
one person coordinating the overall picture.
     
    In the interest of brevity I again ask that you listen to the concerns of 
the American Institute of Certified Public Accountants, and not institute 
rules restricting services of our profession.
     
Sincerely,
     
W. Thomas Brooks
E-mail:  Brooks1972@aol.com