Subject: File No. S7-16-98 re: Amendment to Rule 102(e) Date: 8/12/98 10:55 PM Mr. Jonathan G. Katz, Secretary Securities and Exchange Commission I would like to comment on the proposed amendment to Rule 102(e) regarding the definition of improper professional conduct. (File S7-16-98) I am a CPA in Industry, working as an Assistant Controller for a division of a publicly traded company. I feel that the proposed rule is unnecessarily onerous in that a single negligent act could lead to censure or sanctions by the SEC. While CPA's must exercise extreme care in their work to maintain the public trust, we are human and will make errors in judgement or careless mistakes. I concur with the AICPA's proposed definition of improper conduct which states that the CPA has knowingly violated a professional standard, deliberately disregarded an applicable standard, or has demonstrated a pattern of improper conduct. Sincerely, Ellis Perry Zidow, CPA