Date:    09/19/2000  10:13 AM

Subject: Reference file no. S7-13-00
 
I am a CPA in a small firm in Garden City KS, licensed in the states of 
Colorado, Kansas and Nebraska. Several state societies of CPA's including 
Colorado are considering the same changes. The CPA profession is changing 
rapidly. Our clients depend on us for audits as well as consulting services. 
The consulting services are a natural extension of audit services because of 
our knowledge of the client. For independence rules to require involving 
another firm for consulting services is also inefficient and more expensive 
to clients. To make such a drastic change on such short notice as is 
proposed by this rule without more study is absurd and appears to be a 
knee-jerk reaction at best. Furthermore, I have not found any mention of 
real evidence that non-audit services actually compromise attest quality or 
independence. Wouldn't it make sense for the AICPA's Independence Standards 
Board address the issue in cooperation with the SEC after further study?
     
I strongly urge you to reconsider this proposal and the effects it will have 
also on the small firms.
Gary Schlappe, CPA
Garden City KS