The meeting appears to have contradicted Pitt's past pledge "to avoid even the appearance of impropriety in instances where such meetings could be misconstrued," said Reps. John D. Dingell (Mich.) and Edward J. Markey (Mass.), the ranking Democrats on the Committee on Energy and Commerce and the subcommittee on telecommunications.

Pitt gave lawmakers that assurance earlier this year after it was reported that he met privately with the heads of Xerox Corp. and the KPMG LLP accounting firm while the SEC was investigating both for possible securities fraud. Pitt had represented KPMG as a lawyer in private practice.

The Democrats' Oct. 3 letter was prompted by a Washington Post report that Pitt sought the meeting with Goldman's Henry M. Paulson Jr. to discuss how Goldman and other firms could restructure to eliminate conflicts of interest that result from their dual roles providing investors with research on companies and helping those same companies sell stock to investors.

The SEC is reportedly investigating whether Goldman issued misleading research reports and how Goldman allocated shares in initial public offerings to companies that used the firm's banking services.

Pitt's meeting with Paulson did not include representatives of the SEC's enforcement division, which is responsible for investigations.

"[T]he exclusion of enforcement staff signals to firms under investigation by the Commission that they can influence the course of inquiries by making their case directly to Commissioners," Dingell and Markey wrote. "That you requested this particular meeting . . . only heightens our concern about your judgment," they added, asking Pitt for an explanation.

An SEC spokesman declined to comment.

Lucas van Praag, a spokesman for Goldman Sachs, said "there was no discussion of any enforcement matter" at the meeting.

However, sources at the SEC and in the financial industry said any settlement of enforcement actions could depend on what steps investment banks are required to take to restructure their businesses.

Also at the meeting were Pitt's chief of staff, Mark Radke, and the SEC general counsel, Giovanni P. Prezioso, sources said..

Under ethics rules, SEC officials are supposed to recuse themselves from matters that involve former clients. Sources said Prezioso is supposed to recuse himself from matters concerning Goldman Sachs. Reached by phone this week, Prezioso would not comment on the meeting or on his restrictions.

Others familiar with the meeting said Prezioso thought he did not have to recuse himself because Goldman Sachs itself was not discussed, only how the company and its competitors might change the operations of their research and investment banking business to avoid the types of conflicts the SEC is investigating.

In another development [Friday], House Minority Leader Richard A. Gephardt (D-Mo.) and two other senior Democrats urged Pitt not to bow to pressure from the accounting industry by rejecting pension fund executive John H. Biggs for the chairmanship of a newly created board to police the industry. Biggs has called for tighter restrictions on corporate auditors.

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