September 18, 2000

Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Reference File No.: S7-13-00

Dear Mr. Katz:

On June 27, 2000, the United States Securities and Exchange Commission approved the issuance of a major new rule proposal that would force a restructuring of the accounting profession and radically alter independence requirements for accounting firms that audit SEC registrants.

The purpose of this letter is to express my opinions of why the passage of that proposed rule would seriously damage the overall accounting profession. The following points highlight my concerns:

For the above reasons and many more, I urge you to actively work to prevent the passage of this ridiculous rule.

Thank you for your consideration of this urgent request for fair and intelligent legislation.


Pete Palmer