Author:  Steve Moses 
Date:    08/14/2000  3:55 PM

Subject: Reference file No. S7-13-00

I am a CPA employed as the CFO of a non-public company for the past 4+ 
years.  Prior to that, I spent 17+ years with a major public accounting 
firm.  My audit experience included a number of SEC registrants.  Because of 
my background and current status as an investor only relative to SEC 
matters, I feel that my comments are unbiased and not self serving.
 
First, I believe that the independence rules are in need of reform for 
reasons of appearance and actual conduct.  The independence violations 
reported in the financial press are embarrassing and cast serious ethical 
questions about the CPA firms wholesale violation of the current 
independence rules.  Something needs to be done to create practical rules 
that work and then enforce those rules.  I agree with the safe-harbor for 
minor unintentional violations.
 
I agree that certain consulting services may impair the independence of the 
various auditing firms.  I'm not convinced that the current proposal 
addresses all of the areas of meaningful concern and restricts itself to 
only those areas.  Professionals who exercise professional judgment must be 
allowed to exercise that judgment within reason.  
 
The American Institute of Certified Public Accountants ("AICPA") has long 
established standards that champion the public good and also allow for the 
exercise of professional judgment through the standard setting process.  It 
is always better to self regulate than to have outside regulation if the 
profession wishes to attract and retain the brightest students and business 
people.  The retention and attraction of top people will do more to maintain 
and improve audit quality then any rules and restrictions possibly could.
 
Since these issues are not new, the AICPA has a committee solely devoted to 
independence standards, and no empirical evidence exists to show that these 
standards will improve audit quality or reduce audit failures, I urge you not 
to rush these rules through a lame duck administration.  The timing at the 
end of a presidential term, with a short comment period states to me and many 
others that these far reaching changes can not stand up to the scrutiny of an 
extended comment period or the attention of executive as well as legislative 
branches that are involved and mindful of the consequences of such action.
 
I urge you to table the current proposal and then work closely with the 
AICPA to create workable standards that truly protect the public interest 
without undue costs to the Registrants you regulate or the CPA firms that 
audit those registrants.