Date:    09/16/2000  10:51 PM

Subject: Comment%20File%20No.%20S7-13-00%20-%20Testimony

     
I am writing you regarding the CPA independence rules changes that the SEC is 
or will soon be proposing.
     
While I support independence for CPAs these proposed rules go much too far. 
Please do not support these rules as proposed. The proposal would not allow 
CPAs to provide additional consulting services to their audit clients. My 
practice is auditing local units of government. They often need additional 
services to enhance their effectiveness. As their auditor, I am typically in 
the best position to understand their needs and provide the most cost 
effective consulting to them. If I was not able to do so, I feel that in many 
cases their needs would go unmet. 
     
A major national study of corporate executives conducted by the Independence 
Standards Board concludes that stockholders and corporate executives are 
confident in their auditor's independence and are satisfied with the overall 
quality of financial
reporting. Their is no current problem that would cause such onerous rules to 
be adopted.
     
I urge you to halt the proposed rules changes.
     
Thank you for your attention,   Joe Heffernan