Subject: File No. S7-16-98

Date:    8/14/98 10:56 AM
     
     
Dear Mr. Katz:
     
I believe that Rule 102(e) negligence standard with respect to 
accountants contravenes public policy, treats accountants in a 
discriminatory manner, and would actually diminish the vital role of 
accountants as guardians of the financial reporting system.  Accountants 
should sanction accountants only in the event of a knowing and/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. 
Accountants are professionals, but they are not gods.  We do make honest 
mistakes occasionally.  
     
Janet Casady, CPA