September 12, 2000

Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Re: File No. S7-13-00

Dear Mr. Katz,

This is to advise you that our Firm is not in favor of the proposed regulation before the SEC prohibiting non-audit services. Our concern is that the proposed rule may set a precedent for other regulators. Although our firm does not audit SEC registrants, the proposed SEC rule could be viewed as a new model by other regulators.

The SEC's proposal to restrict the services offered by accounting firms represents a fundamental restructuring of a profession that has served the public for many years.

We believe that the public will be better served by allowing businesses to choose whom they can buy services from without governmental intervention.


Charles E. Harper, Jr.
Certified Public Accountant