Date:    09/20/2000  11:35 AM

Subject: Reference File No: S7-13-00; Revision of the Commission's Au

Dear Sirs:
     
I am in full support of the Securities and Exchange Commission's ("SEC" or 
"Commission") proposed rule amendments regarding auditor independence. 
Whereas the growth of revenues from consulting services has far exceeded the 
growth of accounting revenues, consulting fees have come to be more 
important than audit fees to those firms that are now selling non-attest 
services to audit clients. Consulting services has emerged as a very 
lucrative business and, as a result, the importance of audit and attest 
services has greatly diminished in such firms.  The separation of accounting 
and consulting services as outlined in the proposed rule amendments will 
halt the transformation of the accounting profession into a business of 
consulting services.  
     
The integrity of the accounting profession is dependent on independence. 
Auditors must be independent in fact, and in appearance.   Without 
independence, fair and efficient markets are not possible.  Restricting the 
services offered by accounting firms will safeguard auditor independence and 
therefore, will ensure investors that the data upon which they rely is truly 
independent and reliable.  Thus, public confidence in the accounting 
profession and in our markets will be greatly enhanced.  Investors will be 
more confident that reoccurrences of past accounting fiascoes will not be 
possible.  
     
As a large, national consulting firm (formerly a CPA firm) comprised 
primarily of CPA's, Ryan & Company long ago recognized the inherent 
conflicts associated with simultaneously being an advocate and a watchdog. 
Our founder made the decision to forego performing attest services so as not 
to compromise our position as advocates for our clients.    The core focus 
of the accounting profession should be that of accounting and auditing, not 
that of cross-selling non-audit services.    
     
The SEC's scope of services rule should be adopted as proposed as it is in 
the best interest of all. 
     
     
Sincerely,
     
Tanya W. Taylor
Tax Consultant
Ryan & Company
221 North Kansas 
Suite 1502
El Paso, Texas 79901