September 19, 2000

Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street NW
Washington DC 20549-0609

RE: S7-13-00

Dear Mr. Katz:

We urge the Commission not to adopt its proposed rule regarding revision of auditor independence requirements but rather to allow the necessary time for thoughtful consideration and discussion among all interested parties-the SEC, the Public Oversight Board, the accounting profession, and the public-of the Panel on Audit Effectiveness's recommendations. And, we ask that the Independence Standards Board be allowed to do its work in creating appropriate standards for independence and scope of services. To adopt the proposed rule and circumvent the bodies already established to identify and develop solutions in these areas is both preemptive and unnecessary.

Many will argue the merits of the proposed rule. We encourage full debate so that the public is properly protected, and the existing system is permitted to work.


The Board of Directors

/s/ Charles P. Fredrick, President

Cc: Chairman Arthur Levitt
Commissioner Paul R. Casey
Commissioner Isaac C. Hunt, Jr.
Commissioner Laura S. Unger
Colorado Congressional Delegation Members
CSCPA Public Company Practice Committee