Date:    08/29/2000  3:59 PM

Subject: Comment File No. S7-13-00
 
Dear Members of the SEC:
     
In reference to the debate regarding auditor independence I am of the opinion 
that accounting firms developing valuations for a client and then auditing that 
same information is a conflict of inbteresta dn should be stopped.
     
Accounting firms should be allowed to compete for general business however not 
for business in which they also perform the audits.
     
Sincerely
     
Thomas O. Willingham
Willingham Associates Inc.
7800 Laurel Ave.
Suite 100
Cincinnati, OH  45243