From: Brausen James R.
Sent: Friday, August 14, 1998 2:20 PM 

Subject: File No. s7-16-98
     
Jonathan G. Katz
Securities and Exchange Commission
450 5th Street N.W.
Washington, DC 20549-6009
     
Dear Mr. Katz,
     
Please except this letter as my opposition to Rule 102(e).
While practicing accounting in industry over the past 20 years I have   
learned that this profession is far from an exact science.  The   
accountants judgement is essential in doing the job and the quality of   
the decisions/judgements made are what defines the accountants   
reputation.  Errors in judgement do and will occur as will less than   
optimum decisions.   Conclusions that there was an error or poor decision   
are usually made in hindsight.
It is important that 'improper professional conduct' not be tolerated.   
 But errors in judgement should not be considered as 'improper   
professional conduct'. The state societies, state board of accountantcies   
and the AICPA all monitor the quality of work done by accountants.  The   
reputations of these governing bodies are also vital to the accounting   
profession and provides the foundation for the interest in the self   
monitoring of the profession.
The accounting profession does hold itself to very high standards and   
disciplinary action is warrented for 'improper professional conduct' .   
The accountants should not be subject to more risk or exposure than   
directors or officiers of a company by the SEC's proposed rule.
The ability for accountants to uses there best judgement without fear of   
SEC disciplinary action is essential to keeping the world turning.  The   
wording of any rules put in place must distinguish between 'errors in   
judgement'  vs. 'conscious or deliberate actions'  that could mislead the   
users of the information.
     
Sincerely,
     
Jim Brausen, CPA
 (Idaho - CP1252)