Date:    08/15/2000  2:52 PM
Subject: S7-13-00

To Whom It May Concern:
     
Arthur Andersen, et al., are reckless and irresponsible.  They can't 
have it both ways:  They either are consultants, or they are not 
consultants.
     
These folks have a simple choice to make:  They can offer compliance 
services, period, or not offer compliance services, period.  If they 
offer them, then they should be made to get out of peddling all manner 
of consulting services.  If they don't, they can sell whatever clients 
are willing to buy.
     
The first responsibility of the CPA providing attest and valuation 
services is to be independent--in fact, word, and deed.  The relentless 
cross-selling and -delivery of consulting services that goes on in bigger 
firms--national, regional, local--is a massive conflict of interest.  It 
compromises independence.  How can the auditors be 'independent' if 
they're passing on the internal controls of a computer system their 
colleagues on the consulting side sold and installed?  This is just 
goofy.
     
The current rules also encourage incompetence.  In one CPA firm near our 
market area, I know first-hand that the audit partners and tax partners 
try to dictate valuation results to the valuation guy.  In another 
office of that same firm, the partner-in-charge nominally specializes in 
IT services, except during the first five months of each year, when he 
morphs into a tax-and-audit guy.  Late last December, he asked me for 
help on a valuation report for an ESOP client.  Two weeks ago, he called 
me wondering how to do a fairness opinion--and said he thought he ought 
to charge for two or three hours of time for it (when he should have 
charged about $50,000).
     
If the compliance people don't like low margins and ungrateful clients, 
they can get out of the business.  No one requires them to be there. 
But if they opt to be there, then they need to be as pure as the driven 
snow.
     
Don't let these bullies push you around.
     
Most sincerely,
     
Warren D. Miller, CPA-ABV, CMA