Author:  Mike Weeks  
  Date:    8/11/98  8:31 AM
          
  Subject: File No. S7-16-98
          
  I am a certified public accountant, inactive.  My current position is Executive
  Vice President of a public company, with no direct responsibilities for the
  financial information that our company produces and provides our shareholders
  and the investing public.  I offer that background so that you may know my
  perspective and relative "independence" to any impact of the proposed Rule
  102(e) by the Commission.

  I disagree strongly with your logic that CPA's should be held to a standard
  different from other professionals involved.  We have long had standards for
  professional negligence, and to propose a more stringent one, which appears to
  my non-legal eye to clearly be outside of the definitions of law presently on
  the books, is irresponsible of the commission.

  I suggest that you limit your definitions to intentional, knowing, or 'gross'
  negligence, consistent with applicable professional standards and law. Do not
  attempt to add to that negligence related to nebulous "unreasonable" violations,
  those that are difficult to define, and that are often simply "human" mistakes.
  In my view, the Commission is overstepping its given responsibilities in
  attempting to define conduct of a certified public accountant, just as it would
  likewise be in error in attempting to define acceptable professional
  (technically speaking) conduct of an attorney.

  I recommend that the Commission limit their definitions regarding professional
  conduct to those already established for the accounting profession.