Date:    09/06/2000  4:58 PM

Subject: S7-13-00

I am writing to protest the proposed SEC rule prohibiting non-audit services to 
a CPA firm's attest clients.  My firm serves smaller SEC registrants that 
require considerable assistance to comply with SEC reporting rules.  The drastic
rule proposed by the SEC will effectively eliminate our ability to provide this 
service, which benefits the SEC, the client, and the investing public.
     
Small registrants cannot afford to hire the expertise necessary to comply with 
the many regulations promulgated by the SEC and other regulators.  They rely on 
their CPA firm to perform not only the audit function, but also advise them on 
the many systems, controls, and policies they must follow to be successful in 
business and comply with the regulations.
     
It will be nearly impossible for these registrants to segregate their single CPA
firm relationship into multiple relationships so they can comply with the new 
independence rules.  CPA's will refuse to provide audit services or require 
excessive fee increases due to the inefficiencies imposed by these regulations. 
Most CPA firms below the Big Five in size will stop serving SEC registrants, 
which will further restrict the access of smaller companies to reasonably priced
audit services.
     
The SEC has proposed these new rules with no empirical evidence to support it's 
presumption the prohibited services compromise independence.  This proposal also
makes it likely that even the largest audit firms will not be able to retain the
specialist non-CPA experts that are necessary in today's technology driven 
environment to perform quality audits of large and small enterprises.
     
This quest for theoretical purity will reduce the quality of audits, limit 
access to auditing services, and be devastating to the investing public the SEC 
is supposedly protecting.
     
Regards,
     
Gregg D. Jordshaugen
     
Gregg D. Jordshaugen
Moss Adams LLP
Bellevue, Washington