Date:    08/30/2000  12:56 PM

Subject: S7-13-00

August 30, 2000
     
     
     
I have recently learned of the major new rule proposal issued by the United 
States Security and Exchange Commission ("SEC") on June 27, 2000.  As a 
shareholder in a CPA firm, I am convinced that this rule proposal will have 
a severe and detrimental impact on my firm, its employees and the 
accounting profession as a whole.
     
It appears the SEC has issued this rule without establishing any evidence 
that non audit services provided by auditors have created any problems with 
audit quality.  Without establishing that a problem exists, it seems 
excessive to propose rules which would dramatically alter a profession.  In 
fact, the current panel on Audit Effectiveness of the Public Oversight Board 
which was formed at the request of the SEC concluded that, "both the 
profession and the quality of audits are fundamentally sound."  The panel 
said it could find no evidence that the provision on non-audit services has
impaired audit quality.  What then is the SEC reasoning for the rule proposal?
     
Further, I think this proposal will effect CPA's working in the industry as 
it will not allow public companies free choice in seeking competent outside 
professional services.  In fact, it is quite possible that public companies 
will replace audit firms, which have been doing a consistently good job for 
them, in order to obtain services from the auditors non-audit colleagues.
     
Under the proposed rules, accounting firms would be precluded from entering 
into almost any joint venture or partnership since the accounting firm's 
independence could be impaired as a result of the activities of other 
parties in which it may have only an immaterial investment.
     
I cannot imagine that young accounting professionals will seek positions in 
the accounting industry when upward mobility has been dramatically limited, 
as it would be under this proposal.  The best candidates will certainly 
seek employment elsewhere further damaging the public accounting profession
and further damaging the integrity of the audits the SEC is concerned about.
 Overall, I believe this rule will seriously damage my firm and my
employees even though we do not currently audit publicly owned companies. 
Not only for the reasons stated above, but also the prospect that other 
regulatory bodies will follow the SEC's lead should this proposed rule 
become law and restrict accounting firms in a similar fashion.  It seems 
preposterous that a profession which is functioning properly and providing 
good quality services throughout the financial markets is to be 
fundamentally altered as it would be in this proposed rule.  Please do not 
approve this proposed rule.
     
Very truly yours,
     
     
     
Jack Quinn
     
JQ/rmb