Subject: File No. S7-16-98
Author:  Albert Dennington
Date:    8/12/98 4:30 PM
     
     
I believe that Rule 102(e) negligence standard with respect to accountants 
contravenes public policy, treats accountants in a discriminatory manner, 
and would acutally diminish teh vital role of accountants as guardians of 
the financial reporting system.  It would be far better, for investors and 
accountants alike, if the Commission instead were to sanction accountants 
only in the event of a knowing or conscious and deliberate violation of 
applicable professional standards or a pattern of misconduct that can be 
shown to create the required risk to the Commission's processes or the 
financial reporting system.