Subject: File No. S7-16-98

Date:    8/13/98 1:52 PM
     
     
This message is regarding the above referenced Proposed Rule amendment to 
Rule 102(e) of its Rules of Practice.
     
I am not a CPA that provides information to SEC or practices before it, 
however the proposed rule appears to be highly aggressive in that it 
provides broad interpretations of what constitutes "improper professional 
conduct".
     
I believe that any such amendment should provide definitions that prevent 
fraudulent, deceptive practices but provide allowances for unintentional 
errors.
     
Best regards,
Keith L. Boroch, CPA