Date:  8/10/98  11:27 AM
          
    Subject: File No. S7-16-98
        
    As a member of the AICPA and and employed by a company that is an SEC
    Registrant, I am alarmed by the the SEC's proposal to penalize CPAs who make an
    error in judgement.  I stongly agree with the AICPA's proposal to define
    "improper professional conduct" as conduct demonstating that a professional is
    substantially unfit to practice befroe the commision by the following criteria:

    a.)  Knowingly violates applicable professional standards 
    b.)  consciously and deliberately diregards aplicable professional standards, or
    c.)  Engaged in a a course or pattern of conduct showing repeated failure to
    conform to applicable professional standards, but on where it is established
    that such conduct poses a threat to the integrity of the commission's processes
    (or the financial reporting sytem).  A single act of mere negligence (i.e an
    error in judgement) would not meet this standard.

    These opinions are my own and do not represent those of my employer.

          ~~~~~~~~~~~~~~~~~~~~~~~~~~
          Thoamas M. Tomlinson, CPA
          Property Accounting Manager
          Archer Daniels Midland
          (217) 424-4925
          email: tomlinson@corp.admworld.com
          ~~~~~~~~~~~~~~~~~~~~~~~~~~