Subject: File S7-13-00 Date: 08/23/2000 4:50 PM My name is Jeffrey Picker. I am a CPA and currently serve as Treasurer and Chief Financial Officer of GUARD Financial Group, in Wilkes-Barre, PA As a CPA in private industry I am totally opposed to the proposed SEC rules regarding auditor independence. I spent 25 years in public accounting as an audit partner in two major, international accounting firms and do not beleive that the proposed rules are either necessary or appropriate. As the Treasurer and Chief Financial Officer of a privately held company for the past five years, being on the other side has not changed my opinion of auditor independence. I do not understand the rush to change long established relationships. This issue has been thoroughly investigated by the SEC and other independent bodies over the past ten years and there has been no consensus for such actions. The cost and impact of this change would be radical and is, in my opinion, ill timed. The public will not be better served and many firms, public companies and numerous innocent employees of the accounting firms will be adversely affected. Please allow the system to deal with this issue. The proposed spin off of consulting services by the major accounting firms will have an adverse impact on firm personnel as well as clients. Audit committees and boards of directors have sufficient guidance and authority to recognize any impairment of auditor independence. In addition the proposed regulation will deprive those same committees and boards the freedom to choose their consulting service providers if it happens to be within the same firm that provides the annual audit. Thank you