Date:    09/18/2000  3:23 PM

Subject: S7-13-00

I am writing to protest the proposed SEC rule prohibiting non-audit services to 
a CPA firm's attest clients.  My firm serves smaller SEC registrants that 
require considerable hand holding to comply with the SEC reporting rules.  The 
rule proposed by the SEC will effectively eliminate our ability to provide these
services which benefit the SEC, the client and the investing public.
     
Small registrants can't afford to hire the expertise necessary to comply with 
the many regulations promulgated by the SEC and other regulators.  They rely on 
their CPA firms to perform not only the audit function but also advise them on 
the many systems, controls and polices they must follow in order to be 
successful in business and comply with the regulations.
     
It will be prohibitively difficult for these enterprises to segregate their 
single CPA firm relationship into multiple relationships in order to comply with
the new independence rules.  CPA's will refuse to provide audit services or 
require excessive fee increases as a result of the inefficiencies imposed by 
these regulations.  Most CPA firms below the Big Five in size will stop serving 
SEC registrants, further restricting the access of smaller companies to 
reasonably priced audit services.  
     
The SEC has proposed these new rules without empirical evidence to support its 
presumption that the prohibited services compromise independence.  This proposal
also makes it likely that even the largest audit firms will be unable to retain 
the specialist non-CPA experts that are necessary in today's technology driven 
environment to perform quality audits of enterprises of all sizes.
     
This quest for theoretical purity will surely reduce the quality of audits, 
limit access to auditing services and hurt the investing public which the SEC is
supposed to protect.
     
Sincerely,
     
Robert E. Ryker