Date:    10/16/2000 2:52 PM
     
     
SECURITIES AND EXCHANGE COMMISSION
     
     
17 CFR Parts 210 and 240
     
     
[Release Nos. 33-7870; 34-42994; 35-27193; IC-24549; IA-1884; File No. 
S7-13-00]
     
     
RIN 3235-AH91
     
     
Revision of the Commission's Auditor Independence Requirements
     
     
AGENCY: Securities and Exchange Commission 
<http://www.sec.gov/rules/proposed/34-42994.htm
     
The issue is the SEC's proposed rule that would prohibit firms,
which audit SEC registrants from providing non-audit services to their 
audit
clients.  This would negatively impact all CPAs and their clients, 
regardless of size.
     
Updating the independence rules is probably warranted, but the sweeping 
overhaul as
proposed goes far beyond anything that is necessary.
     
We all know that CPAs take our profession's independence standards and the 
responsibility to represent the public interest seriously.  It's an 
attribute and responsibility that defines us as a profession.  Since 
there's
been nothing to demonstrate any significant problem in this regard, we 
struggle to figure out just what is the motivation for the SEC to pursue 
such a dramatic change.
     
I wanted to inform you of my disapproval of this proposal.
     
Thank you,
     
Lisa A. Springer, CPA
51540 Fairchild Rd.
Chesterfield Twp., MI 48051