Date:    09/18/2000  9:47 AM

Subject: SEC ruling on independence

As a practicing CPA working for a midsized CPA firm, I can tell you that 
performing consulting services and attestation services (audits, reviews) 
does not cause a conflict or an independence issue in our firm. In fact 
performing additional services for an audit client (such as computer 
consulting, internal control systems review and advise, and other 
consulting such as strategic planning,  management advice, etc.) helps (1) 
to better assess risk at the financial statement and account balance or 
transaction level, (2) to know the client and their situation better that 
could not be done under an audit situation only, and (3) helps to improve 
the client control and performance situation so that our audit risk is 
reduced. We do not perform regular SEC engagements. However, I am afraid 
that an SEC prohibition on consulting services and performance of audit 
services could find its way down to smaller firms or non-SEC engagements. 
In my opinion, such a prohibition would be costly to the clients and to the 
economy. We are at a time in which the detection of fraud and misstatements 
is at a heightened interest and need. The performance of additional 
services for audit clients can only increase our opportunity to detect 
these types of misstatements.
     
Eric P. Wallace, CPA