Date:    09/18/2000  8:19 AM

Subject: File no. S7-13-00
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        I would like to urge you not to approve the proposed SEC rule regarding
the
limiting of the services CPAs can provide to audit clients.  As a member of 
the AICPA and NCACPA, I am aware of the strict guidelines already in place 
that govern the independence issue and the services that can be provided. 
We are essentially a self-governing profession and I feel that as a 
profession, we have been successful at adhering to the rules we set for 
ourselves.
        While it may appear that this rule will only effect large businesses and
large accounting firms, the states often follow the federal lead.  This rule 
may subsequently be interpreted to apply to all audit clients and accounting 
firms.  The trickle down effect of the proposed rule will devastate many 
small accounting firms such as the firm where I am employed.  Many of our 
clients use a variety of the services we provide because they know that we 
are competent and professional.  To take these services away will also cause 
hardship on these clients who will have to build that type of relationship 
with yet another CPA or begin to do their own accounting work (which they 
may not have been able to do well in the first place).
        Thank you for taking the time to read this letter and consider my
position.
I do not feel that the arguments in favor of this rule outweigh the wide 
reaching negative impact on the accounting profession as a whole.  Please do 
not approve this rule.
     
Sincerely,
     
Christopher Cole, CPA