Date:    08/24/2000  10:47 AM

Subject: S7-13-00

I am writing to protest the proposed "scope of services rule" being considered 
by the SEC. In the interest of improving CPAs' independence, the SEC proposes to
limit the ability of CPA firms to provide non-attest services to attest clients.
 The decision to move forward with this rule is not based on facts or empirical
evidence.  No evidence has been presented that suggests that a broad scope of 
services impairs audit effectiveness. 
     
If this rule is enacted, small registrants such as those served by our firm will
find it increasingly difficult to obtain cost effective audit services.  By 
forcing a company to chose to hire a firm solely as its auditor or solely as its
provider of consulting services, the rule could cause a company to engage 
providers of one or the other type of services who are less qualified than the 
single-source firm with whom the company had previously dealt on an exclusive 
basis.  The rule would even go so far as effectively banning a CPA firm from 
acting as its audit client's advocate before the IRS.
     
Regional alliances or cooperative agreements between accounting firms could 
result in each firm being required to be independent of each other firm's attest
clients.  The resulting impairment of the effectiveness of these types of 
alliances would limit middle market companies' access to the broad range of 
services offered by these alliances, which individual member firms might not be 
able to provide on their own.
     
In conclusion, the SEC's proposal attempts to fix a problem that does not exist.
 Our profession has successfully provided investors with reliable, independent
data they need tom make investment decisions for over a century.  The SEC rule 
would have a governmental agency tell CPA firms what services they may offer and
tell those firms' clients from whom they can buy services.  This represents an 
unwarranted intrusion into the free market system.
     
This scope of services rule must not be allowed to go forward.
     
JEFF
     
Jeffrey P.  Maxwell
MOSS ADAMS LLP