Author:  "Doug Carter"
Date:    09/19/2000  11:08 AM

Subject: File No S7-13-00

To: SEC
     
I heartily endorse this rule to regulate management advisory services by 
firms who provide audits.  It has been often stated in seminars which I 
have attended that firms will offer audit services at below cost rates in 
order to get a foot in the door to provide management advisors services. 
Certainly, in this type of environment there is the potential for 
significant influence on the audit staff by the management advisory groups 
efforts.  I have always considered the performing of an audit function by a 
firm where the same firm, or related firm,  was performing management 
advisory services to represent an undefendable conflict of interest. Please 
correct this ethical oversight.
Thank you,
D. J. Carter, CPA