From: Stephen Schultz
Sent: October 10, 2006
Subject: File No. S7-06-03

Dear SEC Chairman,

My name is Stephen Schultz, and I am the Director of Internal Audit for Graybar Electric in St. Louis. We are a non-accelerated filer. I am contacting you to query on the status of proposed rule 33-8731 (Internal Controls over Financial Reporting in Exchange Act Periodic Reports on non-accelerated filers and new public companies). The comment period ended Sept. 14. The delay proposed will not affect us, however, whether our external auditor will have to opine on our internal controls in 2007 will. The cost of this work will have to be budgeted for accordingly.

I have reviewed a sample of the comments related to this proposed rule and have discussed it with our external auditors. In both instances the proposed rule is viewed favorably. However, until it is made official we don't know for sure.

Thank you,

Stephen Schultz