Subject: -File No. S7-16-98 Author: at Internet Date: 8/20/98 5:59 PM Mr. Jonathan G. Katz Secretary The Securities and Exchange Commission 450 5th Street, N. W. Washington, DC 20549-6009 Dear Mr. Katz: Regarding the proposed change to Rule 102(e) of the Rules of Practice, I would like to inform you that I am strongly opposed to the change that is being put forth by the SEC. I believe that this change is too strong and that it would subject CPA's who serve in industry to undue risk for SEC enforcement action relative to errors in judgement in connection with the preparation of financial statements. I support the position of the AICPA and its suggested language for the change to Rule 102(e). This language supports the position that misconduct occurs whenever a "willful intent" is present and can be established. I urge you to strongly reconsider the AICPA's position regarding the proposed change to this rule.