Date:    09/19/2000  2:46 PM

Subject: File S7-13-00

Jonathan G. Katz, Secretary
Securities and Exchange Commission
     
RE: Proposal to Limit Scope of CPA Services
     
Dear Jonathan G. Katz, Secretary,
     
There's an issue before you that could impact every CPA, and potentially 
every business in Iowa.  The issue is the SEC's proposed rule that would 
prohibit firms that audit SEC registrants from providing non-audit services 
to their audit clients.  This would negatively impact all CPAs and their 
clients, regardless of size.
     
If adopted this restrictive standard could easily affect every firm's ability 
to provide almost any non-audit service.  This could include accounting and 
bookkeeping services, payroll services, systems design and implementation, 
valuation, management, consulting, financial planning, expert witness and 
other services that are the growing areas of service for most firms.  If you 
adopt this rule, it's likely that "harmonization" or comparable 
rules/regulations by individual state boards of accountancy, the Department 
of Labor, the General Accounting Office, and bank regulatory agencies would 
be a byproduct, impacting the ability of local firms to fully serve the needs 
of their clients.  In short, the breadth of services a firm could offer would 
likely be limited to one: audit or non-audit services!
     
It is my opinion that this proposal has more far-reaching effects than you 
realize.  I ask that the proposed rule not be approved.
     
Sincerely,
     
     
Jeffrey C Van Maanen, CPA