Author:  <jmullins@mswplc.com> 
Date:    08/15/2000  3:39 PM
Subject: File Number S7-13-00

I have just recently been apprised of the above referenced rule and submit 
my comments.  I have been a practicing CPA for 32 years and have watched 
the profession evolve over that time.  There is a need to make some 
regulatory changes but to take such draconian action is liken to killing 
the patient in order to save it.
I have personal, practical experience in the filed dealing with real live 
people not assumptions and abstract ideology.  My clients have over the 
years looked to me for advice in a myriad of non-related subjects because 
they trust me and frankly, I am schooled, trained and qualified to discuss 
these matters.  Your proposal to severely restrict non-audit services will 
set a harmful precedent and leave the consumer, the one you are attempting 
to protect, with severe restrictions in their choices.   I have only to 
look at the Investment field and recognize some serious shortfalls relating 
to public protection, yet perpetrations occur on a daily basis.  I have 
often wondered how in the world a regulatory body would not require a 
person soliciting investments to have absolutely no formal training through 
a seat of higher education is beyond me.  Yet, the public relies on your 
office to protect them.  How can they be protected when all they have to do 
to set up their shingle is either fill out an ADV or pass an NASD exam and 
go out hawking their wares to an unsuspecting public.  I would liken this 
to me as a CPA practicing without the formal training necessary to do my 
job.
So now, here comes Proposed Rule S7-13-00 that is intended to protect the 
public but will most assuredly do the opposite.  I fell the proposal is not 
without its' merits but far too reaching.  You will in effect render the 
entire CPA profession to Tax practitioners, which is going by the wayside, 
and opinion auditors.  There is no question in my mind that other 
regulatory agencies will pick up on your cue and really tie the professions 
hands behind their backs.  I would even go so far to assert this proposal 
could be the end of the CPA profession.  Look around and you will see, less 
and less young people want to become CPA's.  The thing that attracts the 
younger generation to the profession is the ancillary services we provide. 
I am 57 years old now and 4 years from retiring.  You proposal will have 
little effect on me but I hate to see a profession I am proud to be in end 
up dyeing a slow death.
Please consider my points as you go on to further regulate an already 
severely regulated profession.