Date:    09/18/2000  8:38 AM

Subject: Reference file # S7-13-00

I am an over 40 year member of the AICPA & Missouri State CPA group and have 
been in public and private practice for 45 years.
     
In recent years changes have occurred in the practice of public accounting which
concern me greatly in regard to the relationship between audit operations, and 
the consulting practices and tax operations of public practice accounting firms.
     
Having read a number of national articles and state society bulletins regarding 
the proposed regulations by the SEC regards these internal CPA firm operations, 
it is my personal consideration that additional controls are required, but 
overkill is not necessary.
     
The primary objective of the SEC is to provide protection to the investing 
public from problems within the operations of the securities market and to 
monitor the supplying of information to the investing public on the operations 
of the companies in which the public invests.
     
Therefore, I feel that restrictions on certain of the operations of public 
accounting firms doing audits of public corporations are duly required.  Those 
firms who perform audits of public corporations, regulated by the SEC, should 
not be allowed  to perform consulting service for the same corporations and no 
member of any public accounting firm doing audit work on a public SEC regulated 
company should ever invest in that client
.
In the large area of non SEC regulated companies, the regulation of accounting, 
consulting and tax services provided by the public accounting firms in 
unnecessary, unneeded, and such regulation would represent federal intervention 
into the relationship of businesses and their desired and needed important 
service providers that would cause serious detrimental short and long term 
problems for those private businesses.  When a private company considers an IPO,
these relationships would have to be re-arranged.
     
Thank you for considering my comments.
     
Alan H. Goodman, CPA - 1636 Holling Dr. -  Omaha NE 68144