Date:    09/17/2000  6:29 PM

     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D. C 20549-0609
     
.
     
    Re: Proposed Rule: Reference File No S7-13-00
     
Dear Jonathan G. Katz:
     
I am writing to urge you to review Proposed Rule: Revision of the 
Commission's Auditor Independence Requirements.
     
We are about to regulate the accounting profession right out of existence. 
This rule focuses on the appearance of independence but not independence in 
fact. The possible perceptions of independence will result in micromanaging 
the profession, impairing accounting firms ability to respond to the needs of 
the clients, and jeopardizing the accounting firm's ability to continue to 
operate. This is especially important to a small firm whose primary business 
is non-audit services. Audit clients may recruit the services of the 
accounting firm performing the audit to implement the recommendations 
received as a result of the audit. Because at that instance the firm that 
performed the audit may be the most qualified to assist in the 
implementation, having knowledge of the company and areas needing 
improvement. While some services may be non-audit in nature they may have a 
direct or indirect effect on financial records. Which could contribute to a 
more effective subsequent year audit. 
     
Thank you for the opportunity to express my concern regarding the Proposed 
Rule, Revision of the Commission's Auditor Independence Requirements.
     
     
Sincerely,
     
     
Ludella Lewis CPA