Date:    09/01/2000  5:02 PM

Subject: Reference File No.: S7-13-00 
 
     
                                            September 1, 2000
     
Jonathan G. Katz, Secretary 
Securities and Exchange Commission 
     
Dear Secretary: 
     
     I wish to comment regarding your proposed rule barring the accounting 
profession from performing other valuable services for the same client for 
whom they perform audit functions.
     
    I am a CPA with 20 years of experience.  I have seen many times the 
increased effectiveness of an auditor who has obtained a more thorough 
knowledge of the company through other services for that company.  CPA's DO 
NOT feel in any way a diminished sense of independence merely because they 
perform other necessary business services for a client.  It is part of the 
inherent integrity of a CPA which precludes us from jeopardizing our 
independence with regard to a client for whom we are performing an audit. Our 
own peer reviews and self-regulation place a high degree of importance on 
maintaining independence both in fact and in practice.
     
    Your proposal is in complete contrast to the recommendation of the Panel 
on Audit Effectiveness of the Public Oversight Board, who was formed at the 
request of the SEC.  They found no evidence that the provision of non-audit 
services hurt audit quality and concluded that in numerous instances, 
non-audit services contributed to a more effective audit.  Even the SEC has 
admitted that there is no empirical evidence that non-audit services have 
compromised audit quality or auditor independence, nor ever caused an audit 
failure.  Why impose regulations which are not needed and may actually impede 
the best performance of auditors?
     
    This proposal would also decrease the level of competence among the CPA 
profession who would choose to remain in auditing, only to be limited to 
auditing.  The "best and brightest" will choose other accounting and business 
careers where their abilities would lead to broader career opportunities.
     
    Please do not allow this proposal to go forward.  This is an inherently 
flawed proposal which could harm the very segment of practice of which you 
are concerned.  Thank you for your consideration of this matter. 
     
                                    Yours truly,
     
                                        Barbara L. Franko
     
                                    Barbara L. Franko, CPA