Date:    09/22/2000 1:50 PM
     
     
I am sending this letter in the message. The message that I had sent to you 
previously was a Word document and I do not know why it did not come through as 
one. 
     
Thank you. 
Barb Adams, Administrative Assistant to S. Brian Jurasek, CPA
     
WILLIS & JURASEK, P.C., CPAs
Post Office Box 39, Jackson, MI 49204-0039 
(517) 788-8660  Fax (517) 788-9872
     
     
September 20, 2000
     
     
Mr. Jonathon G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
     
Dear Mr. Katz:
     
I have followed with interest the SEC's discussion on proposed rule amendments 
regarding auditor independence.  We are a local CPA firm operating out of 
Jackson, Michigan and have done so for the past 30 years.  We take great pride 
in our ability to recognize our client's needs.  None of our clients needs 
revolve around an audit of their financial statements for public presentation; 
rather these audits are for regulatory or financing purposes.  By spending time 
with our clients during the off season, (any time other than when audit services
are being performed) doing consulting, helps their business and allows us to 
gain a better understanding of their financial condition and internal controls 
and makes us better auditors.   We are fully aware of the AICPA regulations 
regarding independence and have turned down or referred out engagements due to 
independence issues.  
     
I am concerned that the SEC's current proposal regarding independence would have
a trickle down effect to our firm much like big GAAP, little GAAP on some 
accounting requirements.  With big GAAP, little GAAP we are forced to study and 
consider many FASB and SAS that are not relevant to the size of client that we 
serve.  In the same respect, many of our clients, as well as their financing 
sources, trust our judgment and want us to perform certain non-audit services 
since we are familiar with their operations.  On a continual basis, we weigh our
independence conflicts with the need to assist our clients in their business 
endeavors and we typically err toward the conservative side.
     
It seems to me the biggest danger to the investing public is the inability of 
historical financial statements to accurately reflect value of new economy 
companies and their economic volatility in the market place.  As management 
information systems become more complex, a thorough understanding of the 
business from a consulting/auditor point of view is an asset to most companies. 
Setting up restrictions on consulting may also impose an artificial barrier for 
many students considering the accounting profession.  The quality of auditors 
may decrease with less considering the profession.  Also, many states and other 
regulatory agencies will pass blanket regulations based on SEC requirements.
     
We ask that you take great care in the proposal that you pass in that you not 
only consider the need for auditor independence, but also the need to satisfy 
the issues facing small business in this country.  Thank you for your 
consideration.
     
Sincerely,
     
S. Brian Jurasek
     
S. Brian Jurasek, CPA
Managing Principal
     
SBJ/ba