Date:    09/08/2000  7:51 AM

Subject: Fwd: S7-13-00

I am writing to protest the proposed rule prohibiting accounting firms from 
providing non-audit services to audit clients. 
     
There is no evidence that the independence of accounting firms has been impaired
by providing non-attest services to clients.  In actual practice specialized non
attest services provided to audit clients add to the Firm's wealth of specific 
client knowledge about  processes and business issues which create a huge 
benefit of helping to focus audit resources and reduce audit engagement risk. 
This can be extremely important to the independent auditor and improves overall 
audit quality.  Having a better knowledge of a client's business issues and 
complex processes when planning and conducting the annual audit produces better 
audits.
     
Engagements for non attest services also keeps the accounting firm and client in
closer contact throughout the year and more issues germane to the annual audit 
can be resolved on a contemporaneous basis.  Smaller clients benefit from a 
closer working relationship with its accounting firm.  These  typically are 
truly business relationships rather than a vendor/customer relationship with an 
outside  company to perform a specific task or project.  This proposal will 
cheapen the image of the audit and segregate access to non attest services.  In 
many cases non attest elements of the business relationship with the clients' 
accounting firm  can be key to a smaller clients' success.  
     
Clients will not benefit from this proposal.  It is not by accident that many 
audit firms provide non attest services to their existing clients.  Clients 
frequently choose a sole source for practical reasons such as cost, familiarity 
with their operations, perceived value, and confidentiality of competitive 
advantages.  Clients are free to choose the best providers of these services. 
Why should clients be denied this freedom of choice common throughout a market 
economy?   
     
The consequence of this proposal would deny cost effective access to key 
services or at a minimum impose substantial additional administrative burden on 
management resources with no pay back or actual benefit. 
     
This proposal also has far reaching unintended consequences such as the effects 
on business relationship established by accounting firms with other providers of
non attest services.  The short time line for imposing these rules does not 
allow for a proper deliberation of the effects.
     
Please do not implement  this proposal or at a minimum delay implementation to 
study the effects more thoroughly.  Thank you.
     
     
Harry Phillips, CPA
Moss Adams LLP
1702 Broadway
Tacoma, Washington  98402-3206