Public Company Accounting Oversight Board

1666 K Street, N.W

Washington, DC 20006

Telephone: (202) 207-9100

Facsimile: (202) 862-8430

www.pcaobus.org

February 15,2008

Barney A. Richmond

Chairman

American Capital Holdings

1016 Clemmons Street

Suite 302

Jupiter, FL 33477-3305

Dear Mr. Richmond:

Your recent letters to Chairman Mark W. Olson and Angela Desmond (dated December 17, 2007, January 1, 2008, and January 2, 2008) concerning American Capital Holdings ("ACH") and Wieseneck, Andres & Company, P.A. ("Wieseneck"),  have been forwarded to my attention. I write to respond to one aspect of your letters'. I understand that Claudius Modesti, the PCAOB's Director of Enforcement and Investigations, will separately respond to another aspect of your letters.

You refer to PCAOB Release No. 104-2005-117 ("the Release"), which is the publicly available portion of a PCAOB inspection report on Wieseneck. You suggest that the Release is critical of ACH's accounting in two respects, and you request consideration of your position before the PCAOB takes a position in the matter. Please note that (1) the Release indicates that PCAOB inspectors reviewed audits of two of Wieseneck's ten issuer audit clients, neither of which the Release identifies; (2) the Release is not critical of any audit clients' accounting, but instead describes failures by Wieseneck, in two respects, to perform audit procedures necessary for Wiese neck to have a sufficient basis for an audit opinion; and (3) the Release does not assert that both of those auditing failures were present in each of the audits reviewed. In addition, the PCAOB issued the Wieseneck inspection report in October of 2005, and there is no ongoing process with respect to its content.

Should you have any questions concerning PCAOB processes, please feel free to call me at (202) 207-9034.