Date:    08/24/2000  11:59 AM

Subject: Reference file No: S7-13-00

I am sending you this e-mail in response to your request relative to 
comments on the above proposal.
     
I am an individual practitioner (for most of our profession is composed of 
individual practitioners as well as small firms in public accounting) and 
for many of us, the prospect of not providing all types of services to our 
audit clients would be adverse to us making a reasonable living and not very 
cost effective for our clients.
     
I am aware that PERCEPTION can sometimes be construed negatively as it 
relates to one's belief system.
     
But to restrict the public to use some other professional for non-audit 
services when their current CPA provides audit services is not in the best 
interest of the public.  For to use another firm to provide non audit 
services can be quite costly.  For who knows the operation of a entity best? 
The CPA that povides the audit service for that entity knows it best and 
such services can be more cost effective if their auditor provides such a 
service. (In other words, that additional cost will not be passed onto the 
public).
     
I don't believe that an accounting firm's independence has to be impaired 
just because an entity may use the firm for other services.  Of course, the 
PERCEPTION of providing such services is not one of true independence!  But, 
I beg to differ! For independence is a state of mind!
     
If the SEC wanted to really bring about TRUE INDEPENDENCE  for the so called 
perception of the public, then the SEC should set up a 'Regional Trust Fund' 
that all publicly held companies would contribute to on a prorata basis and 
all auditors would not only be forbidden to have any investments in such 
entities they would also be required to draw their audit fees from such 
fund.  Accordingly, the independence issue would be resolved.
     
If you wish to contact me, I can be reached by phone at 757-467-6193.
     
Sincerely...William R. Brown, CPA