Date:    8/11/98
          12:45 PM
          
          Subject: File No. S7-16-98
         
          In response to the invitation to comment on Proposed Amendment to Rule 102(e) of
          the SEC Rules of Practice, I take issue with certain aspects of this proposal.
             While I agree that disciplinary action is warranted in cases of conscious and
          deliberate violation of applicable professional standards, this rule could be
          extended to cases of ordinary negligence and errors in judgement. It fails to
          adequately define the extent of violation to which the standard is applicable.
             This rule also holds accountants to a higher and more rigorous standard than
          our counterparts in the legal profession.  No justification can be given to
          support this level of discrimination against the accounting profession.
             As a Certified Public Accountant employed in industry, this rule can only
          serve to inhibit my free exercise of judgement with only the best of intentions.

          Daniel S. Kuerner, CPA
          Texas License #39018