Author:  Terry Deeley 
Date:    08/30/2000  3:52 PM

Subject: S7-13-00 Scope of Services Proposal for Accounting Firms
 
Dear sirs, I am responding to the proposed scope of services rule applying 
to accounting firms performing audits for SEC registrants. I believe action 
on this matter should be suspended until such time as proper empirical 
evidence is obtained to support the SEC position. I have not seen any 
evidence nor did the Panel on Audit Effectiveness of the Public Oversight 
Board that would support the SEC position. I personally believe that the 
performance of non-audit services contributes to a more effective audit.
     
A point to consider as well is the effect that forcing accounting firms to 
choose between either providing only audit or non-audit services will cause. 
If a firm becomes solely dependent on audit fees for survival, then the 
quality of audits will suffer greatly and the public interest will be far 
from met.
     
I appreciate your consideration. Thank you.