Confederation of British Industry

18 December 2002

Mr Jonathan.G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington DC 20549 - 0609

Dear Sir

Proposed Rule : Implementation of standards of professional conduct for Attorneys
Section 307 Sarbanes - Oxley Act of 2002

The CBI is the leading UK business association for UK and other companies carrying on business here. Most UK companies with listings in the United States are members of the CBI.

We are writing on behalf of CBI member companies in support of the representations made to you regarding the position of UK lawyers and attorneys by the Law Society of England and Wales, particularly so far as Section 307 of the Act and the SEC's proposed Rule might apply to non - US lawyers and attorneys employed by UK companies.

We are also supportive of the representations being made to you by some of the UK's leading law firms, and on behalf of the London Investment Banking Association whose members operate in the US securities markets as well as London.

The conclusion must be that there is a strong case to exclude non-US attorneys from the operation of Section 307 of Sarbanes - Oxley ; certainly at the least substantially to modify and minimise the application of the proposed Rule to them.

We are particularly interested and concerned from the standpoint of non - US attorneys who are employees of UK companies.

Yours faithfully

for Confederation of British Industry

CBI Company Affairs