February 16, 2007
I am a CPA and the CFO of an insurance holding company with one insurance company subsidiary and a small agency operation. Other than these companies, we have no other operations.
Our insurance company subsidiary is examined by the insurance department of our domiciliary state every three years, and may be examined more frequently if they deem it to be necessary. It would be helpful and reasonable if the final guidance could address the ability of management to rely on governmental examination reports as part of the evaluation needed to support Management's Report. Such examinations are very thorough and costly themselves, as we are required to pay for the expenses of these examinations. Such examinations should be a tool management can rely on in its evaluation of internal controls.
The interpretive guidance concerning section 404's application to non-accelerated filers should be of great assistance to me and my small staff in preparing for the issuance of the required Management Report. However, even if this guidance is issued in the next couple of months, it is highly unlikely that we will be able to take the steps necessary to complete this Management Report without considerable reallocation of our staff resources and incurring additional costs with third party vendors.
I would like to request that the SEC delay implementation of the Management Report for an additional year. This should allow time for the guidance to be issued, evaluated and understood by both companies and auditors, and new plans made for completing the required report. I also ask for consideration regarding the ability of management to rely on government examination reports in its evaluation of internal controls.
Thank you for your consideration.
Mark C. Hart, CFO
Chandler (U.S.A.), Inc.