Author: Allen A. Hodges Date: 8/10/98 10:06 PM Subject: File No. S7-16-98 Proposed amendment to Rule 102(e)) Attn: Jonathan G. Katz, Secretary Securities and Exchange Commission With regards to your intent to amend the rule that governs the conduct of accountants in practice before the SEC, I urge you to adopt the approach proposed by the AICPA rule making petition and implement a rule which would provide for the sanction of 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 a significant risk to the Commission's processes or the financial reporting system. It is not reasonable to consider simple errors in judgement to be a basis for sanctions against an accounting professional. Thank you for your consideration in reviewing my comments.