Date:    09/19/2000  3:57 PM

Subject: Reference file no. S7-13-00

I recently became aware of the SEC's desire to limit the scope of a CPA's 
practice.  Even more concerning is that numerous State Boards of Accountancy 
also seek to inact similar rules.
     
As a practicing CPA for over 20 years I have seen first hand what effect 
increased government regulation and control has on our lives in general and 
small business in particular has produced.
     
What is most disturbing about this particular assault is that I have seen no 
evidence that such a problem exists.  It appears the SEC is, in fact "proposing 
to fix a problem that does not exist".  Furthermore, CPA's have to most active 
and ethical Standards of any profession that I am aware.  The Independence 
Standards Board already addresses this very issue.
     
I believe that at a minimum, my profession needs much more time to measure and 
determine the impact such a rule will have.
     
Thank you.  
     
Respectfully,
     
     
     
Michael S. White,
Certified Public Accountant