Date:    8/26/98  11:19 AM

Gentlemen,
I am writing to express my opposition to proposed amendments to Rule 102(e) 
of the Rules of Practice as such amendments affect the determination of when 
an accountant engages in professional misconduct.
     
The proposed rule would lower the negligence standard to a level which will, 
or could, include even one error in judgement and will allow measurement on 
a retrospective, un-evenhanded basis.
     
The amendment should have much more clearly defined standards for "improper 
professional conduct" as conduct which clearly demonstarates that as 
professional is substantially unfit to practice before the Comission.  These 
standards should include provisions for a clear demonstration that the 
professional;
        *       knowingly and repeatedly violated professional standards or

        *       engaged in a pattern of conduct that repeatedly violated
professional standards before any sanctions could be assesed.
     
Further, these rules should apply to ALL the professionals associated with 
filings, including (heaven help us) lawyers, investment bankers and even 
CEO's (see WSJ article "When CEOs Can't Add Up the Numbers", p. A19 August 
19, 1998), not just to accountants.
     
The proposed rules discriminate against accountants, especially all those in 
industry and certain of those who also happen to be officers and/or 
directors, and will serve to weaken their role as guardians of the integrity 
of the financial reporting system.
     
David. D. Gathman