Date:    09/01/2000  4:09 PM

Subject: Comment File No. S7-13-00 - Testimony

I fail to understand your proabition on doing writeup (or bookkeeping or 
compilation) work for SEC clients- as long as the CPA dosn't make manigement 
decisions.
     
This has, for non-publicly held clients, always proven to be a way for the CPA 
to obtain a better understanding of the client's accounting system.  Some small 
registranrs need this service-  since it is not cost justified to keep all the 
necessary accounting staff on the payroll.
     
I also don't see the need to prohibit CPA's from helping to design accounting 
systems for their clients.  Again, the CPA will better understand the system.
     
In addition, I see no instances of wide spread "loss of indipendence" by most 
CPA firms.  If some firms have gone astray, punish them-  not the whole 
profession.
     
I believe your efforts would be better spent trying to get financial analysists 
not to cause registrants to manage earnings.
     
Sherman L. Rosenfield, CPA
Miami, Fl.