Cara Heller, CPA
7913 South 2940 West
West Jordan, Utah 84088
Phone (801) 566-9538

August 24, 2000

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

Dear Sir :

The purpose of this letter is to communicate my opposition to the proposed SEC rule concerning the scope of services performed by Independent Auditors (CPA's). I feel strongly that this concept is extremely short-sighted and will be counter-productive to your efforts.

Certified Public Accountants (CPAs) have diligently earned their time-honored reputation of integrity and honesty in the work that they do. They have done an admirable job of governing themselves, without external regulative and legislative intrusions.

The proposed rule would undermine the current system of providing high-quality auditing services to companies, whether public or not. Accounting firms would practically abandon their assurance lines of business, as they would effectively have to choose between auditing or consulting services. Our company uses KPMG for our professional services, and we frequently require the non-auditing services that they provide. With the passing of the proposed regulation, we would not be able to procure the level and quality of non-audit services, as KPMG would not able able to provide them (if we retain them as our audit firm). The cost of using an additional firm to assist us with our other financial service needs would be prohibitive.

The SEC will be eliminating our choice, and that is completely unfair and unwarranted.

Before I came to work at Wheeler Machinery Company, I was an auditor at KPMG (although I did not audit Wheeler Machinery). I entered the auditing field because I felt that I would obtain a solid, broad exposure to accounting fundamentals. But even more importantly, I believed that my audit experience would entertain future opportunities to bigger and better positions, especially within a national CPA firm. I would have never entered the auditing profession if I knew that I would be an auditor for my whole career. I graduated Magna Cum Laude in my college accounting class, and my other classmates were motivated in similar ways.

If the SEC regulation passes, the brightest accounting students will not enter the auditing profession, as it will drastically impede their upward mobility. Nobody has dreams of being the best auditor in the world, the best accountants will certainly choose the non-auditing fields, for that is where the interesting assignments and the best salaries are.

I am proud of my CPA status. History has proven that we CPAs have governed ourselves prudently and properly. Free market forces have always proven to be the best form of change, increased government regulation is not necessary. If the SEC believes that there is a problem with the quality or independence of audits, (no evidence exists to support this position) then the proposed ruling is not the appropriate way to address the problem.

Please do not approve the scope of services rule. It will adversely affect my profession, and eliminate my company's freedom of choice for our audit services.


Cara Heller, CPA
Financial Reporting Manager, Wheeler Machinery Company
Downtown Chapter President of Utah Association of CPA's (2000-2001)