Date:    08/22/2000  11:25 AM

Subject: S7-13-00

I would like to register my disagreement with the proposed SEC rule prohibiting 
non-audit services to CPA firm's attest clients.  The rule proposed by the SEC 
will effectively eliminate my firm's ability to provide this service.  The key 
beneficiaries of our service includes the SEC itself, as well as the investing 
public.  Both the SEC and investors receive good information efficiently because
we are now able to help our clients with their SEC filings
     
Our SEC clients are small registrants.  As you know by the number of questions 
the SEC raises, SEC regulations are very technical and often beyond the ability 
of small registrants.  They rely on their CPA firms to perform the audit 
function and help them with SEC filing requirements.  This has been the case for
many years.  The unintended (or maybe intended) effect of the proposed rull will
be to have only Big Five firms serving SEC registrants.  
     
Before you decide to finalize this rule, I would ask you reconsider the 
ramifications of the proposed rule.  I believe the proposed rule will not serve 
SEC registrants or the investing public as intended.
     
Paul Onerheim

2707 Colby Avenue, Suite 801
Everett, WA  98201-3510