Subject: PUBLIC COMMENT: Comment File No. S7-13-00.

Date:    07/18/2000 6:57 AM
     
     
I totally support the proposal to maintain the integrity of auditing firms 
when they also provide consulting services to the same client.
     
My experience while purchasing director for a heath care provider based in 
California put me in contact with the companies auditor -- both during 
annual reviews of the department's transactions, and later with projects 
that the consulting side of the auditor's 'skills'.
     
I always felt that a conflict of interest existed between these divisions, 
despite the nominal presence of separation under separate 
managers.  Consulting services, for sure, are lucrative and profitable and 
low risk since failures in progress are always blamed on the client's side.
     
It is best to establish SEC procedures that favor independence and 
competency, when in doubt.
     
I therefore, support the following points as summarized in the SEC proposal:
     
Identify certain non-audit services that, if provided to an audit client, 
would impair an auditor's independence. (The scope of services proposals 
would not extend to services provided to non-audit clients.);
     
Provide a limited exception for accounting firms that have certain quality 
controls and satisfy other conditions; and
     
Require companies to disclose in their annual proxy statements certain 
information about, among other things, non-audit services provided by their 
auditors during the last fiscal year.
     
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Thomas Graves
3609 Schaefer Street
Culver City, CA 90232