Date: 09/06/2000 6:27 PM Subject: Proposed SEC Rule on non-audit clients for CPAs I'm writing to protest the proposed SEC rule prohibiting non-audit services to CPA firm's attest clients. My firm serves smaller SEC registrants that require considerable hand holding to comply with SEC reporting rules. The draconian rule proposed by the SEC will effectively eliminate our ability to provide this service which benefits the SEC, the client and the investing public. Small registrants cannot afford to hire the expertise necessary to comply with the many regulations promulgated by the SEC and other regulators. They rely on their CPA firms to perform not only the audit function but also advise them on the many systems, controls and policies they must follow in order to be successful in business and comply with the regulations. It will be next to impossible for these enterprises to segregate their single CPA firm relationship into multiple relationships in order to comply with the new independence rules. CPA's will refuse to provide audit services or require excessive fee increases due to the inefficiencies imposed by these regulations. Most CPA firms below the Big Five in sizes will stop serving SEC registrants, further restricting the access of smaller companies to reasonably priced audit services. The SEC has proposed these new rules with no empirical evidence to support its presumption that the prohibited services compromise independence. This proposal also makes it likely that even the largest audit firms will not be able to retain the specialist non-CPA experts that are necessary in today's technology driven environment to perform quality audits of large and small enterprises. This quest for theoretical purity will surely reduce the quality of audits, limit access to auditing services and hurt the investing public that the SEC is supposed to protet. Sincerely, Mark C. Tibergien Principal MOSS ADAMS LLP Seattle, Washington