Date:    9/5/98  3:25 PM
 
 Subject: File No. S7-16-98

 Dear SEC:

 I realize this comment is after the deadline for comment but I feel I
 must give you my opinion anyway.

 I strongly disagree with the proposed SEC referenced above.  It allows
 the SEC to use hindsight to judge a person's decisions.  This is wrong
 and unprofessional.  I strongly suggest you follow the recommendation 
 of the AICPA.

 Thank you for your time and consideration.

 William L. Bown