Author:  Steve Patterson 
  Date:    8/11/98
          7:53 AM
          
  Subject: File No. S7-16-98
       
  As a member of the AICPA I must inform you of my opposition to the proposed
  amendment to Rule 102(e) AND my support of the AICPA's position on this matter.

  I refer to information from the AICPA where they have asked the SEC to define
  "improper professional conduct" as conduct demonstrating that a professional is
  substantially unfit to practice before the Commission. Under the AICPA's
  proposed definition, a professional's substantial unfitness to practice before
  the Commission would be established by a demonstration that the professional (i)
  knowingly violated applicable professional standards, (ii) consciously and
  deliberately disregarded applicable professional standards, or (iii) engaged in
  a course or pattern of conduct showing repeated failure to conform to applicable
  professional standards, but only WHERE IT IS ESTABLISHED THAT SUCH CONDUCT POSES
  A THREAT TO THE INTEGRITY OF THE COMMISSION'S PROCESSES (OR THE FINANCIAL
  REPORTING SYSTEM).  A single act of mere negligence (e.g., an error in
  judgement) would not meet this standard.

  As an AICPA member I believe that a Rule 102(e) negligence standard with respect
  to accountants contravenes public policy, treats accountants in a discriminatory
  manner, and would actually diminish the vital role of accountants as guardians
  of the financial reporting system.  It would be far better, for investors and
  accountants alike, if the Commission instead were to adopt the approach urged in
  the AICPA's rule making petition and sanction 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 the required
  risk to the Commission's processes or the financial reporting system.

          As an AICPA member I support the Commission's efforts to protect the investing
          public from untrustworthy or grossly incompetent practitioners, however, the
          proposed amendment does not accomplish this. I also applaud the Commission for
          seeking public comment  for consideration on this important matter.