Date:    10/20/2000  9:33 PM

TO: RULE-COMMENTS at 03SEC
Subject: File No. S7-13-00

Dear Sirs;
     
I strongly feel that auditor independence is an important principle that should 
be vigorously pursued.  I've seen (in non-investing circles) that when a 
company's self-interest is sufficiently large, its contractual interests to its 
customers tends to suffer.  Even the appearance of a conflict of interest should
alarm anyone who relies on auditors to find discrepancies and report them to the
investing public.
     
Please don't allow this issue to die due to pressure from auditors. 
Understandably, they would like to allow their own consulting business to grow, 
even if it's at the expense of public disclosure.  I would rather have full 
disclosure of any irregularities found than to have to guess if I can trust the 
numbers published by various businesses.  I think this is a great issue to 
pursue, and encourage you to do so vigorously.
     
Sincerely,
Phillip David