Date:    09/18/2000  3:46 PM

Subject: File No S7-13-00

As a CPA in private practice, It is my opinion that this proposed rule would 
place extra burden upon
   CPA firm's and would not provide any greater independence between the  client
and auditor.
     
   Also, it is my opinion that this ruling could result in lower independence by
restricting the auditors ability
   to diversify the client base and making the auditor more reliant on the
client will make them less independent.
     
   I am requesting the SEC drop consideration of this rule.
     
   Robert Willey, CPA
    454 Pine Valley
   Oxford, MI 48371