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Subject: File No. S7-16-98
 
Date:    8/16/98 10:17 PM
     
     
Mr. Jonathan G. Katz
Secretary, Securities and Exchange Commision
     
Dear Mr. Katz:
     
I believe that you are well aware of the AICPA's position that a Rule 
102(e) negligence standard would treat accountants in a discriminatory 
manner and diminish the vital role of accountants as guardians of the 
financial reporting system.  I do not believe that the SEC should have 
the authority over the accounting profession as proposed.  I recognize 
the need for a code of conduct and the need to at times censure, but I 
think the lack of clarity in the SEC's proposal would creat an arbitrary 
basis for determining neglignet or improper conduct.
I urge you to please consider the AICPA position and revise your rules 
accordingly.
     
Sincerely,
Wayne Scroggins