Date:    08/23/2000  10:34 AM

Subject: Reference file No.:  S7-13-00

My name is Hua Son.  I am a CPA candidate.  Even though I passed the 
education and the CPA Examination as required, I found from my personal 
experience that to obtain the audit hours as a condition to be certified is 
extremely limited.  These audit hours are not existing for me, unless you're 
the staff accountant, who I am not, of a CPA firm.  Even so, I love the 
accounting profession and always support and cherish the "independence" of 
an accountant.
     
Your proposed rule to modernize the "independence" of an accountant is a 
step in the right direction.  My concern is by adopting the rule, you 
inadvertently restrict the availability of "audit hours" and make them 
harder for a CPA candidate like myself to receive.
     
I have tried for years to receive these audit hours from both internal and 
external CPA firms.  For the internal CPAs, the "independence" rule 
prohibits them from using my in-house talents and expertise.  Externally, 
the responses are negative even when I volunteer my services in exchange for 
audit hours.  It's a catch 22 for me.
     
Perhaps, in the final wordings of your regulation, a firewall or a Chinese 
wall should be established between the audit and non-audit services of an 
audit client when a CPA firm provides both services.  This wall is absolute 
and no room for compromise between the two  CPAs in charge of the 
engagements.
     
Sincerely yours,
     
Hua Son
CPA Candidate