McCartney & Company, P.C.
Certified Public Accountants
2121 University Park Drive, Suite 150
Okemos, Michigan 48864
Telephone: (517) 347-5000 Edward B. Rebman, CPA
fax: (517) 347-5007 Susan J. Schanski, CPA

James E. McCartney, CPA
David S. McCartney, CPA
Randall W. Currie, CPA, CISA
Jeffery A. Irwin, CPA

September 13, 2000

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

Regarding file No. S7-13-00

Dear Mr. Katz:

I would like to take this opportunity to express my concern regarding this proposed new ruling. I believe the change in the scope of services aspect of this rule is not appropriate as it is currently presented. It would unduly limit the choices of clients as to whom they may select for professional accounting, auditing and management consulting services. The independent auditor is in many instances the best individual or firm to provide worthwhile consulting services.

The implication that independence is some how impaired by providing both audit and consulting services to the same client is without basis and actually offensive to a profession that strives to maintain independence. Public opinion is without reproach in regard to the ethical and independent behavior of Certified Public Accountants.

In summary, I urge the S.E.C. to repeal the scope of services portion from the above referenced rule.


Jeffery A. Irwin