September 18, 2000

Rule-comments@sec.gov

Jonathan G. Katz, Secretary
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Re: S7-13-00

Dear Mr. Katz:

I am Executive Vice President of Franklin Covey Co. This letter verifies my opposition to approval of the proposed rule regarding scope of services. In my opinion if this rule is adopted the SEC will damage the accounting profession by subjecting the industry to unreasonable regulation. I also believe the rule as proposed would unfairly limit my choices when seeking outside professional services for our company.

Please reject the proposal as currently drafted.

Sincerely,

Val John Christensen,
Executive Vice President and
General Counsel