Subject: Comment on File No. S7-13-00 Date: 07/07/2000 2:59 PM I would like to comment on the proposed new rules regarding auditor independence (File no. S7-13-00) and the practice of having the same firm provide both Internal and External audits of the same company. First let me tell you that I am a Certified Public Accountant and a Certified Internal Auditor and have been for many years. As an internal auditor I have heard the concern at many internal audit events that the external auditors were replacing the internal auditors and this would lead to lost jobs. Of course the reason the internal auditors were being replaced was that the external auditors did a more efficient job by bringing the best internal audit practices of their other clients with them. Had the internal auditors provided this level of excellence to the employer they may still have been internal auditors at their companies. Second, as an external auditor I often would like to rely on the work of internal auditors but often find that I can not. This is do to insufficient internal audit scopes or under staffing of internal audits. This results in having to perform extra work which I could have done more efficiently do to my knowledge of the client. Finally, auditors of companies that get in trouble for poor accounting policies or practices do not do so because they know too much. It is because they know too little! The external auditors often do not know or understand as well as they should, how the company's systems work. By providing both the internal and external audits, the auditors actually learn more about the company; resulting in better suggestions for improvement and acquiring a better understanding of the preparation of the financial statements and controls relied on to prepare financial statements. I believe external CPA firms should be allowed to continue to offer both internal and external audit services to the same company. Limiting CPA firms to either the external or internal audit inhibits the CPA from knowing more about the company and hampers the CPA from providing a better control to shareholders who depend on the CPA profession to provide a fair opinion on the financial results of companies. Thank you for this opportunity to comment, Dave Roszak 15023 Wildwood Drive Clive, Iowa 50325