Date:    09/19/2000  10:57 PM

Subject: S7-13-00

To whom it may concern: 
     
        This is to express my concern regarding the proposed rule
referenced above regarding auditor independence and non-attest services.  I 
am a practicing public accountant in a local firm in the Chicago area that, 
as a matter of policy, does not work with SEC registered clients.  
However, I am deeply concerned that the proposed rule will impact non-SEC 
clients, particularly small businesses, in their ability to work with their 
accounting firms of choice. 
        Whether applied to SEC or non-SEC clients, there are several
concern with the current proposal:
     
        1. The accounting profession is currently in the midst of a people
crisis.  This has been caused by several factors, including the imposition 
of the 150 hour rule in many states, and the fact that more "glamorous" and 
potentially economic rewarding opportunities exist in today's economy.   If 
accounting firms are put in a position where the only type of work they can 
offer is audits, without the opportunity to get their personnel involved in 
other types of work, this can only accelerate the drain of people from the 
profession.   A lack of talented personnel available to do audits seems to 
me to be a far more serious threat to audit quality than the chances of a 
conflict of interest from the provision of non-attest services by a firm. 
     
        2. If imposed, this rule is likely to result in an increase in the
cost of services for clients.  One of the advantages to a client of using 
the same firm for attest and non-attest services is that information 
learned during the provision of one service may be useful in the provision 
of other services.  If different parties are required to provide these 
services, the learning curve, and consequent cost to the client, is bound 
to increase. 
     
        3. The accounting profession has a legitimate concern that, even if
the proposed rule made sense for SEC clients, it is very possible that it 
would end up being imposed on non-SEC clients as well.  State regulatory 
boards may choose to adopt these rules for all accountants so as to assure 
consistency in their rules.  The effect of these rules would be devestating 
to both small practicioners and their clients, who have traditionally 
relied on their accountants as their primary business advisers.  
     
        4. A firm limited to providing attest services may, in fact, become
more economically dependent on an individual client, thereby having the 
perverse effect of decreasing independence.  
     
        There are additional concerns with the proposed rule, but the above
represent my major areas of reservation.  I urge the SEC to reconsider 
these rules.  Further, if these rules are to become applicable to SEC 
registrants, the SEC should take it upon itself to review the impact on 
non-SEC registrants, and to issue cautions to state boards regarding the 
application of these rules to private clients.  It is incumbent on both the 
SEC and state boards to recognize that the needs of clients in the private 
sector are very different from those of publicly traded companies, and the 
impact of these rules should be considered very carefully before any 
further action is taken. 
     
Sincerely, 
     
Larry Sophian