Date:    09/24/2000  2:36 PM


Subject: Reference File No. S7-13-00
     
Johnathan G. Katz, Secretary
Securities and Exchange Commission
Washington, D.C.
     
Dear Sir:
     
I am writing in support of auditor independence and your proposed rule 
requiring such independence.  My name is Richard Mueller.  I am an 
ordinary small investor without, to the best of my knowledge, an 
interest in accounting firms or business consulting firms.  I am a 
stockholder in a few corporations and own some mutual fund shares.
     
I strongly believe that an investor should be able to depend on audit 
results to be independent and free of real or potential conflict of 
interest effects.  It is impossible for an accounting firm, large or 
small, to be aggressive and diligent validating business accounting 
results while making large sums of money selling the same organization 
optional advice of various sorts and/or performing other services for a 
fee.  A so called Chinese Wall is a joke.  I have been lead down the 
garden path by what I believe to have been faulty accounting so I must 
admit to a personal interest in your proposed rule.  I lost money on my 
purchases of Cendant stock and Rite Aid stock.
     
Another reason that total and complete separation of audit services and 
other services is indicated is management commitment.  Accounting firm 
executives should be in a position to spend their time and dollars 
managing an audit business and not have these mental and monetary 
resources diluted with non-audit business issues.  There is an obvious 
conflict of interest within businesses forced to allocate precious 
budget dollars between audit groups and advice providing sections of a 
company.  I submit that hiring superior accountants will produce 
superior audits, staying up to date and keeping auditors up to date in 
their profession will produce superior audits and managing their 
business with an objective of being efficient and effective as an audit 
business will produce superior audits.  The same of course applies to 
the consulting part of the business.
     
Removal of the conflict of interest problems will also allow managers of 
an organization being audited to save money.  They will be able to 
concentrate on obtaining the best audit services available.  The will 
obtain competing bids from audit firms that will allow cost savings on 
this necessary service.  I expect that most firms will find other 
constructive uses for the savings such as contracting for the best 
possible consulting services.
     
In summary, I strongly support your proposed rule to remove conflict of 
interest problems from the accounting industry.  I also feel that 
implementation of the new rule will provide a win-win situation for 
investors, companies, managers, auditors and accounting firms.
     
     
Thank you,
     
     
Richard Mueller