Subject: Comments re File No. S7-16-98

Date:    8/19/98 8:47 AM
     
     
Dear Sirs and Madams,
     
I believe the SEC's proposed rule defining improper professional conduct for 
accountants is unclear and far too broad.  It appears to place an 
unreasonable negligence standard on accountants practicing before the 
Commission.  The proposal seems to contravene public policy and treats 
accountants in a discriminatory manner.
     
I urge the Commission to with-draw its proposal and adopt the approach 
suggested by 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.
     
Thank you,
Steven P. Berry, CPA

Director of Finance, Mass Storage Division 
Cirrus Logic, Inc.
3100 West Warren Ave., Fremont, CA 94538