Date:    8/12/98
          4:12 PM
          
          S7-16-98
        
          Mr. Jonathan G. Katz, Secretary, SEC

               As a CPA working in industry, I believe that a Rule 102(e) negligence
          standard with respect to accountants contravenes public policy, treats
          accountants in a discriminatory manner, and would actually diminish the
          important role of accountants as guardians of the financial reporting system.
          It would be much better, for accountants and investors alike, if the SEC adopted
          the approach recommended in the AICPA's rule making petition and 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. Your consideration of these comments is much appreciated.

                         Alan M. Ruppelt CPA