Date:    09/14/2000  1:40 PM

Subject: Rule Response file no.S7-13-00

To whom it may concern:
     
As a small accounting firm, I am very concerned about the SEC's proposed change 
to accounting rules related to services provided by independent auditors. 
Eventhough your proposed rule only applies to SEC clients and we do not do any 
SEC work, I am concerned that the same thought pattern will be applied to 
smaller firms and clients in the future.  As  a small firm our audit clients 
generally are small municipalites and regulated businesses.  These entities many
times can not afford a large sophisticated accounting staff.  As such they rely 
on the auditor to provide management advisory services such as preparing 
regulatory filings, preparing projections, providing financial analysis on 
various business opportunities and many other functions.  We go to great lengths
to be sure that we accumulated and provide data, but do not make any management 
decisions.
     
It is my opinion that the current rules, followed correctly, protect the public 
and the clients from independence concerns and that this action by the SEC is 
unnecessary and burdensome.  Please review this proposed rule and reverse any 
action on this rule.
     
Larry E. Garrett, CPA