Subject: No. S7-16-98
Author:  Erling Brakke 
Date:    8/12/98 8:20 AM
     
     
I am responding due to concern over the proposed amendment to Rule 
102(e) of the SEC's Rules of Practice.  The investing public or 
accounting professional will not benefit from a rule that is vague and 
could result in suspension of a professional from practice for simple 
errors in judgement.  I would support an amendment that was clearly 
written and required some form of deceit or intention to misrepresent 
before suspension occurred.
     
Thanks for your attention to this matter.