Date:    09/19/2000  2:31 PM

Subject: S7-13-00

I am Partner with Moss Adams LLP. We are a full service middle market  CPA firm 
that works with closely held businesses and small SEC registrants. I have read 
the proposed changes that the SEC has made and do not agree with their rule 
prohibiting  non-audit services to our firm's attest clients. 
     
I have reviewed the findings of the Public Oversight Board who concluded that 
our profession and audit process are fundamentally sound. It was also their 
opinion that the clients benefitted from non-audit service. Our clients often 
engage us to assist them in a variety of projects. In many instances, we are the
only professionals who can meet their immediate needs. 
     
The SEC proposal has a significant impact on the CPA profession. Most firms 
below the Big Five will stop serving SEC registrants, which will drive up the 
price for attest work due to lack of competition. 
     
The SEC should reconsider their proposal. As it stands, it will hurt the public 
and our profession more than help it. 
     
Regards,
     
Christopher G. Schmidt