Date:    08/02/2000  5:59 PM

Subject: Reference File No. S7-13-00

I am writing to advise you of my opposition to the SEC's scope of services 
proposal.  This proposal could cause a restructuring of the entire 
accounting profession and could seriously hurt accounting firms and their 
clients.
     
Most dangerous for accounting firms like mine is the likely prospect that 
the proposed rule would set a precedent for other regulators.  Even 
accounting firms that do not audit SEC registrants could be impacted by 
these new rules.  The proposed SEC rule could be viewed as the new model by 
state boards of accountancy, as well as federal (e.g. banking and ERISA) 
and other regulators.
     
I am also concerned about the relatively short comment period related to 
this proposal.  The comment period of 75 days is not adequate to properly 
address this far-reaching and highly complex proposal including responding 
to questions, collecting and analyzing a great deal of data and considering 
alternative concepts for regulating auditor independence.
     
It is my understanding that the SEC has not mentioned any concerns about 
the scope of services proposal in any of its last 10 reports to 
Congress.  In addition, the Panel on Audit Effectiveness of the Public 
Oversight Board, a Panel that was formed at the request of the SEC, 
concluded that, "both the profession and the quality of audits are 
fundamentally sound."  The Panel said that it could find no evidence that 
the provision of non-audit services has hurt audit quality.  On the 
contrary, it concluded that in numerous instances non-audit services 
contributed to a more effective audit.  In light of this information, I do 
not understand why the SEC is pursuing this course of action.
     
I appreciate your consideration of my letter.
     
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 
Garth M. Tebay, CPA, CVA
Tebay Mosley Associates, LLC
6455 Wheatstone Court
Maumee, OH  43537