Subject: File No  S7-16-98
Author:  Jay Shah
Date:    8/13/98 7:45 PM
     
     
I am writing this to express my views regarding the proposed amendment 
to Rule 102(e).
     
Based on my reading of the AICPA letter dated August 6, 1998,  the 
proposed Rule 102(e)(1)(ii) leaves significant room for interpretation of 
"improper professional conduct".  I agree that improper conduct should 
not be tolerated under any circumstances, however, the definition of what 
is improper should be examined carefully.
     
I would urge you to reconsider this rule, as it may shift the focus to 
more 'CYA' type behaviour rather than making sure that the information 
is accurate.