Subject: Proposed Amendment to Rule 102(e) - File No. S7-16-98
Author:  Gene White
Date:    8/11/98 5:59 PM
     
     
I support the position of the AICPA with regard to the proposed amendment 
to Rule 102(e).
     
I agree that disciplinary action is warranted against an accountant who 
commits an intentional or knowing violation of applicable professional 
standards.  I also agree that a reckless violation - properly understood as 
reflecting a conscious and deliberate disregard of applicable professional 
standards - should be subject to sanction.  Knowing or reckless conduct may 
give rise to an inference of a threat to the Commission's processes (and thus 
the financial reporting system), thereby justifying the imposition of 
sanctions.
     
On the other hand, I do not agree that a single act of negligence - which 
the proposed amendment may well be interpreted to encompass - should ever 
constitute "improper professional conduct" for purposes of Rule 102(e).
     
I hope you will reflect upon these comments and the views of the AICPA 
prior to finalizing the proposed amendments to Rule 102(e).  If you have 
any questions regarding these comments, please contact me at 704-548-2358 
or gene.white@colaik.com.  Thank you.