August 18, 2000

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

Via e-mail:

Re: Reference File No. S7-13-00


The SEC is erroneously making its decision on prohibiting non-audit services from CPA firms without the appropriate facts or research. None of the studies conducted to date have concluded that such would be appropriate. Actually, one conducted by the Panel on Audit Effectiveness indicated that, in general, clients are better served by non-audit assistance from their CPA firms.

The SEC is putting an unreasonably short length of time for this discussion (75 days), specifically at a point in time when the members of Congress are distracted by their re-election process. A topic this major and all encompassing should have an extended not restricted public comment period.

I believe that promulgation of this rule as it stands would harm the public companies themselves by not having the resources of their CPA firm available to them. It would devastate and change an entire profession. This profession, over the past 100 years, has served the public in a professional and diligent manner and, by its audits, has contributed to the viability of the US capital markets, which are the most prominent in the world. It makes more sense to me to let the newly created Independence Standards Board do its job. Require the Public Oversight Board to "beef up" the peer review process and put teeth in the existing laws regarding adherence to independence requirements. In the rush to regulate the SEC has intentionally or unintentionally been avoiding congressional oversight and precluding meaningful public participation.

Very truly yours,
Amper, Politziner & Mattia, P.A.

William Kraut, CPA