Date:    08/17/2000  10:45 AM

Subject: S7-13-00

I am writing to comment on the proposed rules prohibiting accounting firms from 
performing  non-audit services to audit clients.  While our firm presently 
performs no SEC work we are concerned that this ruling may dramatically restrict
our services offered to our audit clients.  We believe state and other 
regulatory agency's will adopt the SEC ruling as one of its own and thereby 
impose these rules on non SEC clients.
     
We believe there is no independence problem with offering non-audit services to 
audit clients.  Indeed, we already have rules in place to ensure independence. 
If there is a problem with this then it is from an enforcement standpoint not 
rule standpoint.  I would encourage the SEC to consider penalizing any firm that
it deems has violated independence rules based on the existing and long-standing
rules.
     
Thank You
     
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Richard Rhoden                       
Rhoden CPA Firm                    
808 Greene Street, Suite 201    
Augusta, Ga 30901                 
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