Subject: File No. S7-16-98
Author:  "Peter A. Lennon" 

Date:    8/20/98 9:01 PM
     
     
It must be obvious to even casual observers that the number of reported 
accounting irregularities and financial statement restatements are at an all 
time high.  Informix, Waste Management, Columbia HCA, Oxford Health, Mercury 
Finance, Sybase, S3, Fine Host, Centennial Technologies,  Micro Warehouse, 
Donkenny, Vesta Insurance, Sunbeam and Cendant are but a few.  As such, I was 
horrified by the request of the AICPA and Richard Miller that the SEC amend Rule
102(e) in such a way that would basically absolve auditors from liability in the
wake the most egregious financial frauds.  Specifically, the Institute's 
assertion that "the investing public benefits from accountants who feel free to 
exercise their best independent judgment" is absolutely ludicrous.  It is surely
no coincidence that reported financial statement frauds have risen to an 
all-time high immediately after the Supreme Court eliminated auditor liability 
for aiding and abetting securities fraud in the Central Bank decision and joint 
and several liabiility for securities fraud was eliminated by the Private 
Securities Litigation Reform Act of 1995.
     
In light of the undeniable cause and effect relationship between raising the 
standard for auditor liabilty and the number of reported finacial statement 
frauds, I completely support the proposed amendment and strongly urge you to 
disregard the self-serving nonsense being put forth by the AICPA and Richard 
Miller, who won't be happy until all auditor liability in the context of 
securities fraud is eliminated.