Date:    09/07/2000  8:16 AM

Subject: s7-13-00

This note is in protest of the proposed SEC rule prohibiting non-audit services 
to a CPA firm's attest clients.  Our firm serves smaller SEC registrants that 
need non-audit services as their business grow.  They rely on us to provide 
these services such as the development of systems, control and policies to help 
them be successful and comply with regulations and laws.
     
It is not effective to have multiple sources for providing these services.  It 
increases costs, takes more time, and may increase the risk to the client and 
investing public as a result.
     
In addition, it is impractical to believe that Company's would want to deal with
more vendors, and that the CPA firms could organize in a way to provide 
different types of services in this manner and keep qualified staff to do the 
work.
     
This does not sound like a well thought out plan and I do not believe it will 
result in better audits and more protection to the investor public.
     
     
Sincerely,
     
     
W. Val Robins