Subject: Ref. File No. S7-16-98

Date:    8/20/98 1:50 PM
     
     
In
 response to the SEC proposed amendment to Rule 102(e) of its Rules of Pr
actice, I offer the following comment.  I applaud the intent to better pr 
otect the investing public from untrustworthy or grossly incompetent pr 
actitioners.  However, I do think the proposed amendment does "single ou 
t" the accounting profession for a more stringent standard of care. Wh 
ile I believe that my profession does generally hold itself to a hi
gher level of ethical conduct when compared to others who practice be 
fore the Commission, I feel it is unjust to stipulate conduct to only on 
e professional body.  I would prefer to be judged on the same basis as le 
gal counsel.
     
Further, should the amendment proceed, I would like to see more 
definitive language that eliminates any possible conclusion that a 
single act of simple negligence might ever constitute "improper 
professional conduct" for purposes of Rule 102(e).  And, finally, I 
think it blatantly unfair that the proposed rule could permit the SEC, 
with the benefit of hindsight, to disagree with any accountant's 
judgement calls made during the preparation of financial statements, or 
in the course of an audit.  I have the education, training and 
demonstrated competency to be licensed as a Certified Public Accountant 
and believe that I have the right to freely exercise my judgement within 
the guidelines of my professional association.
     
Thank you for having permitted me this opportunity to voice my opinions.
     
Respectfully,
Larry D. Cyrus, CPA
Finance Manager, EUS CF/EC
BT Region Americas
Ericsson, Inc.