Date:    08/22/2000  1:16 PM

Subject: S7-13-00
 
As a CPA with experience performing audits and reviews of SEC clients, as 
well as experience working as a Controller for a NASDAQ-listed company, I 
would like to communicate my support for this new rule.
     
It is my opinon that CPAs must be independent, in both fact and appearance, 
in order to properly audit SEC clients.  The public's trust in our financial 
systems would be seriously harmed by the loss, or the appearance of the 
loss, of this independence.  I do not believe CPAs can be both independent 
for audit purposes, and a partner with management for non-audit services.
     
The AICPA currently is mounting an aggressive campaign to have members 
comment against the proposed rule.  The motivation appears to be to protect 
the incomes of CPAs, by allowing them to practice "on both sides of the 
fence".  I believe the long-term interests of CPAs would be better served by 
promoting and enhancing the public's confidence in CPAs to be independent, 
as does the proposed rule.
     
Regards,
Thomas P. Pachl, CPA
Aurora, Colorado