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.