August 16, 2000
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549-0609
     
Re: file no. S7-13-00 - proposed rule governing auditor independence
     
     
Dear Mr. Katz:
     
    The Securities Exchange Commission (SEC) has based its June 27, 2000
decision approving the issuance of a major new rule proposal which 
governs auditor independence without facts or empirical evidence that 
non-audit functions have compromised audit quality or auditor 
independence.  Furthermore, the SEC has ignored the conclusions of the 
Panel on Audit Effectiveness of the Public Oversight Board that "both 
the profession and the quality of audits are fundamentally sound."
     
   I am concerned about the impact this new rule will have as a consumer
of auditor and other CPA related services and the possibility it will 
eliminate my ability to choose the best value for our company, 
regardless of the service.  I ask you to please reconsider the impact of 
this new rule.
     
Sincerely,
     
Timothy K. O'Connor
President
Inns of America
755 Raintree Dr.  #200
Carlsbad,   CA  92009