Subject: File No. S7-16-98.
 
Date:    8/20/98 7:47 AM
     
     
Dear Mr. Katz:
     
I want to respond to the proposed amendment to Rule 102(e) of the SEC 
Rules and Practice, which governs the conduct of accountants and other 
professionals who perform audits or otherwise practice before the 
Commission.
     
It is my hope that the Commission will diminish the power or do away 
with the proposed amendment, which would subject accountants, whether in 
industry or public practice, to discipline by the SEC for simple errors 
in judgment.  I believe that the AICPA is firmly committed to protecting 
the investing public from untrustworthy or grossly incompetent 
practitioners.  The investing public benefits from an environment in 
which accountants are free to exercise their best independent judgment 
without fear that a particular judgment might be viewed as subject to 
sanction by the SEC.
     
One of the challenges faced by all governing bodies, including the SEC, 
is to strike a balance between allowing for independent judgment and 
establishing a standard for disciplinary action as a result of mistakes 
of judgment and negligence.  The AICPA, state Societies of CPAs and the 
respective State Boards of Public Accountancy work to govern our 
industry and protect the investing public from those that are not 
qualified to practice or are reckless in their decision making.
     
Should this amendment be fully implemented into Rule 102(e) as it is 
presently proposed, audit and tax fees from a continuing audit would 
substantially increase.  The steps and costs to take a company public 
would escalate.  The difficulty of conducting day to day business 
affairs should the amendment become effective could be staggering.
     
It is my sincere hope that the SEC will reconsider this proposed 
amendment and therefore not modify Rule 102(e) accordingly.
     
I appreciate your time and consideration in reading this communication.
     
Best regards,
     
Kyle E. Carrick, CPA
Sr. Financial Analyst, International Accounting 
The SABRE Group