Subject: File No. S7-16-98 Comment Letter

Date:    8/18/98 10:27 AM
     
     
August 19, 1998
     
     
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 5th Street, N.W.
Washington, DC 20549-6009
     
     
Dear Sir:
     
I am corresponding to you regarding the SEC's proposed amendment to Rule 102(e) 
of its Rules of Practice.  I appreciate the opportunity to provide my input 
prior to any revisions to disciplinary rules for accountants who practice before
the SEC.  While I understand the need to create greater certainty and 
consistency regarding the application of Rule 102(e), I do not believe the 
proposed amendment appropriately accomplishes these objectives.
     
As a member in industry of the American Institute of Certified Public 
Accountants (AICPA), I support the AICPA's position on the proposed amendment. 
I agree with the AICPA's position that a Rule 102(e) negligence standard with 
respect to accountants contravenes public policy, treats accountants in a 
discriminatory manner and would actually diminish the vital role of accountants 
as guardians of the financial reporting system.
     
I also agree that it would be better if the Commission instead were to adopt the
approach urged in the AICPA's rule making petition and sanction accountants only
in the event of a knowing or conscious and deliberate violation of applicable 
professional standards or a pattern of misconduct that can be shown to create 
the required risk to the Commission's processes or the financial reporting 
system.
     
I believe this matter is of great significance to the accounting profession. 
Again, I appreciate the opportunity to express my views and urge the Commission 
to strongly consider the AICPA's opposition to the proposed amendment.
     
     
     
Very truly yours,
     
W. Randall Dickerson, CPA