Date:    08/22/2000  1:23 PM

Subject: S7-13-00

Dear Sir or Madam,
     
I would like to request that the SEC withdraw its proposed rule S7-13-00, 
prohibiting non-audit services by CPA's to their audit clients.  
     
I am a CPA with a regional firm which serves primarily smaller businesses, 
including some smaller SEC registrants and would-be registrants.  This proposal 
will cause a severe hardship to those small businesses.   Unlike the major 
Fortune 1000 companies, these smaller companies rely heavily on their CPA firms 
for both the audit services as well as non-audit services.  If they are forced 
to hire separate CPA firms for the audit and for the non-audit services, this 
will be extremely costly for them.  Not only will they have to incur duplicate 
fees, but their personnel will have to "educate" two separate groups of CPAs; 
this will place a severe strain on their already overworked accounting staffs 
and cause these companies to expand their accounting departments, at great cost.
     
I know this rule was proposed with good intentions, to benefit the investing 
public.  But in fact it will provice little or no protection for investors, and 
it will not improve the quality of financial information provided to the public.
 Please consider withdrawing this proposal, or at least extending the comment
period until others have an opportunity to point out the harm that this proposal
will cause.
     
Very truly yours, 
     
E. Peter Krier, CPA
     
E. Peter Krier
Moss Adams LLP
PO Box 22650 
Yakima, WA 98907
(509) 248 7750 ext 254
(509) 457 5204 (fax)
petek@mossadams.com