Date:    09/14/2000  1:22 PM

Subject: File no S7-13-00

Sir or madam:
     
The proposed SEC rule governing auditor independence has many problems from 
my point of view:
        1  Non-audit services have not been proven to cause audit failures 
        2  The comment period is much too brief for adequate input
        3  The impact on the financial health of many audit providers will be
jeopardized and accordingly, audit availability lessened
        4  Certain alliances are crucial in today's market place for the sharing
of
information in a timely, efficient, effective manner
     
Although, I do not perform SEC work, I am concerned that the state boards 
may adopt similar rules at the state level.  I and my firm would be 
tremendously impacted if these rule were to be implemented.  I pride myself 
on my firm's ability to adhere to independence requirements and, at the same 
time, provide needed services to our clients.
     
I respectfully submit to you that this rule is a constraint on both the 
provider of services and the recipient without adequate justification.  I 
find no basis for this ruling and request that this rule be negated.
     
Sincerely,
     
Janice B. Smith, CPA
507 W. Clinch Ave.
Knoxville, TN 37902-2104