August 20, 1998



Mr. Jonathon G. Katz, Secretary
Securities and Exchange Commission
450 5th Street, N.W. 
Washington, D.C.  20549-6009


RE:  File No. S7-16-98


Dear Mr. Katz,


I support the Securities and Exchange Commission’s proposed amendment to Rule 102(e) 
of the Commission’s Rules of Practice.  My only comment regards the use of the phrase 
“unreasonable violation” in the definition of negligent conduct.  If “unreasonable 
violations” of applicable professional standards are grounds for Rule 102(e) sanctions, 
then “reasonable violations” must not be grounds for Rule 102(e) sanctions.  I suggest 
either changing or deleting the modifier to the word violations or giving some guidance 
as to what are reasonable violations of applicable professional standards.

Thank you for the opportunity of expressing my opinion.


Best personal regards,




K. MICHAEL CONAWAY, CPA
110 W. LOUISIANA, SUITE 312
MIDLAND, TX  79701