August 21, 2000

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Dear Mr. Katz:

As a member of the public accounting profession, I am quite concerned about the independence rules currently being proposed by the SEC. These rules would prohibit the profession from performing most consulting services for attest clients. My firm is a member of the SEC Practice Section of the AICPA's Division for Firms; however, we perform services for only a few SEC clients. Furthermore, we do not currently perform any consulting services for SEC clients except for tax planning advice. My concern is that the SEC's response to independence problems disclosed at the major accounting firms will result in standards being applied to the rest of the accounting profession that will adversely affect our ability to properly service our clients.

The following points have been identified by the AICPA as reasons why the SEC should not proceed with the proposed independence rules. I agree with the AICPA's assessment.

I urge the SEC to reconsider its stance on the scope of services issue and its effect on firms' independence with attest clients. I do not believe the proposed rules will enhance the quality of audits or benefit the investing public in any way. In fact, the rules may do more harm than good for the reasons stated above.

Very truly yours,

Malcolm C. Taylor,