Date:    08/14/2000  4:13 PM

Subject: S7-13-00

Dear Sir or Madam:
     
I would like to respond to the proposed rule regarding independence of audit 
firms who perform nonaudit services.
     
While serving as a senior accountant for Deloitte & Touche, and currently as 
audit manager for a small regional firm, I have witnessed several instances 
of "rolling over" on issues that affected our clients, for no other reason 
than the apparent conflict sticking to our guns would have caused (thus 
threatening our revenue stream).  Often the logic that the issue was 
immaterial (when many times it was not), or a "reclassification issue" was 
employed by the firm as justification to pass on an item that should have 
been corrected.  While I do not believe that either firm has been willing to 
pass on the really significant issues, there are many others that have 
slipped by to maintain our positive and lucrative relationships.
     
How the public accounting profession can say that their firms are 
independent of an organization, when nonattest revenues are equal to, or as 
is often the case today, greater than the audit fees, I do not know.
     
I believe this rule would result in great hardships on the profession in the 
short run, which should be considered against the benefit of improving our 
apparent and actual independence.  In the long run, it could not help but 
improve shareholder confidence in the audit reports we provide.
     
Sincerely,
     
J. Britton Davis