Date:    8/11/98
          9:32 AM
          
          Subject: File No. S7-16-98
          
	  The proposed amendment to rule 102(e) of the SEC Rules of Practice
          unjustifiably penalizes accountants for errors in judgement.

          As a CPA in industry who prepares financial statements, I am given the
          responsibility of making thousands of decisions each month on the
          classification of transactions in the financial statements.  Despite all
          good faith efforts to accurately record the information both for internal
          and external reporting, mistakes are sometimes made.  While the mistakes
          are not material (and are subsequently corrected when discovered), it is
          disturbing to think that one material mistake could be dealt with as
          harshly as this proposed rule amendment allows.

          The AICPA's proposal to limit disciplinary action to repeated acts of
          negligence, or knowing violations of GAAP and SEC reporting rules is
          preferred.  This proposal would allow for the SEC to accomplish its goal of
          maintaining integrity in the financial reporting system, without punishing
          isolated errors in judgement.

          I believe that accountants, and CPA's in particular, are as a rule, with
          high integrity and strive to follow the professional standards which have
          been set by the FASB and the SEC.  However, we are all human and honest
          mistakes are sometimes made.  It is important for CPA's to have freedom in
          making  judgements  so  that  the  accounting industry does not suffer as a
          whole.

               Sincerely,

               Joel I. Reichbart, C.P.A.
               Director of Finance
               Hilton East Brunswick & Towers

               Member, AICPA, New Jersey Society of CPA's