September 20, 2000
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 5th St. NW
Washington, D.C. 20549-0609
Re: SEC Proposal to Limit Scope of CPA Services
Dear Mr. Secretary:
In regards to the SEC proposal to limit CPA services, we strongly urge that the proposed rules not be approved.
Our firm provides a wide range of valuable services to a client base that is primarily agriculture-related. As you may well know, the vast majority of farmers are struggling to stay afloat and with this proposal you would again be dealing them another deadly blow. They rely heavily on information that is obtained from these services to make the necessary decisions pertaining to their farming operation. Every service from bookkeeping to financial planning is most important to them.
My understanding of the effect of the proposal is that CPA's will not be able to offer non-audit services to audit clients. Agriculture audit clients would be forced to select two CPA firms in lieu of one. Because of the inherent inefficiencies involved with dealing with two firms, it is predictable that the total costs to the client will go up, while the quality of services will go down.
We feel that you should strongly reconsider this proposal and the definite negative effects to the farm economy.
Dave Gerard, CPA
Latta, Harris, Hanon & Penningroth, LLP
Certified Public Accountants