Subject: File No. S7-16-98

Date:    8/20/98 10:56 AM
     
     
Dear Mr. Jonathan G. Katz,
     
We agree with the AICPA's position on the definition of "improper professional 
conduct" in Rule 102(e).  We agree that accountants should only be disciplined 
"in the event of a knowing or conscious and deliberate violation...or a 
pattern of misconduct that can be shown to create the required risk to the 
Commission' s processes or the financial reporting system," not for simple 
negligence.  We believe this restricts the free exercise of independent 
judgment and that responsibility for the discipline of accountants should 
remain with the state boards and professional organizations.
     
Bull and Associates
Austin, Texas