September 1, 2006
-My primary comment is this:
Listen to you own advisory committee. The committee issued 147 page report plus and additional 12 schedules.
Apparently you decided to ignore the recommendations totally. Was this another boondogle wastefull project or did you simply decide to ignore the recommendations because they weren't "politically correct"?
404 impelmentation for small companies is onerous,and detracts from smaller companies ability to compete in a tough marketplace. Why doesn't the SEC comment on the report?
The cost benefit analysis that you started on page 252 is rediculous. The cost of implementing 404 will be greater than our net earnings. Does that make any sense? Does that really serve our shareholders?
Herbert S. Wander and James C. Thyer did a nice job of putting together the committee's recommendations. Dividing the companies into tiers makes perfect sense.
Establishing a new system of scaled or proportional regulation for smaller public companies makes real sense as companies under $128 million in market cap make up 1% of total US Equity market capitalization.
I will ask our CFO to comment on implementation, but what I have a problem understanding is why the commission doesn't comprehend that all companies regardless of size or regulated with one broad brush stroke.