Date:    09/14/2000  8:02 AM

Subject: Reference File No. S7-13-00

Jonathan G. Katz, Secretary
Securities and Exchange Commission
     
Re:File # S7-13-00 Proposed Non-Audit Services changes
     
Dear Mr Katz:
     
I write to express my opposition to the proposed SEC 
rule change to restrict Non-Audit Services a CPA can 
provide to a client when performing Audit Services. I 
believe this proposal would reduce independence in 
audit services instead of increasing independence.
     
The performance of audit services is an extremely 
competitive service. Unlike years ago the profit 
margin for these services is very small. Without the 
revenues provided by Non-Audit Services CPA firms 
could not attract the talent and knowledge required in 
the modern business climate. Transactions by large 
multi-national corporations are very complex and 
require knowledge outside the normal financial 
statements. Under the proposed plan CPA Firms 
conducting audits of these corporations would not be 
able to attract the talent required to understand 
complex financing, recognize risk or the financial 
implications.
     
There is no evidence that the providing of Non-Audit 
Services to Audit clients has reduced independence. 
Indeed I believe that providing Non-Audit Services 
enhances audit quality. The CPA becomes more 
knowledgeable about client operations through the 
provision of other services. This additional knowledge 
improves the quality of audit services.
     
The proposal under consideration is ill advised. The 
public accounting community has an excellent 
self-regulation system. In addition shareholders are 
protected against audit failure through access to the 
courts.
     
I urge the rejection of this proposal.
     
Bernard G. Buerger,CPA
1095 Nimitzview, Suite 302
Cincinnati, OH 45230