Date:    08/16/2000  2:28 PM

Subject: SEC proposed regulations S7-13-00

I am writing you concerning the proposed regulations by the SEC of the 
separation of accounting services provided and auditing services provided by 
a CPA.  The SEC is proposing that the accountant which provided the auditing 
services can not be involved in any other aspect of the clients accounting 
(i.e. Tax work, projections, etc.).
     
This could seriously hurt a small firm and set a precedent  for other 
regulators (i.e. Public Service Commission, County Commissions, etc.). 
Sometimes the auditor has the most in-depth knowledge of how a client operates 
and not to be able to utilize that knowledge could be detrimental to the 
business involved.
     
The SEC is in such a rush that adopted a schedule designed to avoid 
Congressional oversight and preclude meaningful public participation, waited 
until the last minute to push through a radical rule to restructure the 
accounting profession, without permitting informed oversight or policy 
particiaption, limited to 75 days the periofo rcommenting on a far reaching 
and highly complex proposal including responding to more than 400 questions, 
collecting and analyzing a great deal of data, pre-empted the work of the 
ISB, set up three years ago at the initative of the SEC to develop a new 
conceptual framework fo rauditor independence and appropriate implementing 
standards, and not allowed recent reforms to work, including new disclosure 
and audit committee requirements adopted by the ISB, the NYSE , the NASD, the 
American Stock exchnage and the SEC>
     
We ask that you review this hastely made decision by the SEC and urge them 
not to procede.
     
Thank you for your consideration to this matter.
     
Sincerely,
     
Hilarion V. Cann, CPA
159 EAst Main Street
Clarksburg, WV  26301