Subject: File No. S7-16-98
Author:  Mark  Lenz  
Date:    8/15/98 1:56 PM
     
     
With regards to the amendment of Rule 102(e) of your Rules of Practice, I would 
like to have a further clarification of the term "negligent conduct" in the 
excerpt from Rule 102(e) below as it relates to applying judgement in areas of 
accounting.  It is unclear whether a difference in application of judgement when
done in a thoughtful manner and with complete information could be treated under
this amendment as negligent conduct.
     
Thank you for your consideration.
     
Negligent conduct in the following circumstances:
     
                  1.An unreasonable violation of applicable professional
standards that presents a substantial risk, which is either known or should 
have been known, of making a document prepared pursuant to the federal securities 
laws materially misleading; or 
     
                  2.Repeated, unreasonable violations of applicable professional
standards that demonstrate that the accountant lacks competence.**