Date:    08/26/2000  8:32 AM

Subject: S7-13-00

I am a CPA not currently engaged in public accounting.  I am a division 
controller of a NYSE listed company.  I find the proposed rule burdensome and 
anti-competitive.
     
It would restrict our choices for specialized help.  For some issues and areas 
of expertise, there are already limited sources of outside help, and this rule 
would further limit those choices.
     
Further, it appears that the SEC is acting without any evidence indicating that 
there is a problem in this area.  I would think it would be smarter to put 
limited resources to work solving real problems, rather than assuming that there
must be a problem in this area.  From my experience, both in industry and 
previously with a large public accounting firm, the services in question serve 
to improve the quality of audits, if anything, because of the greater 
familiarity with the client.  In 26 years of experience, I have not observed 
even one incident where audit independence and independent judgment were 
compromised.
     
Please count my voice as one opposed to the measures in the proposed rule.
     
Roger Corless