May 14, 2002
Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 Fifth Street
NW, Washington, DC 20549
Re: Proposed Rule, Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports
Dear Mr. Katz:
Delphi Corporation respectfully submits this correspondence communicating our position on the above noted Securities and Exchange Commission (the Commission) proposed rule change.
We support the Commission's proposed rule change. Specifically, we agree with the proposal to shorten the filing deadlines from 45 to 30 days after period end for quarterly reports, and from 90 to 60 days after year-end for annual reports. We agree that shorter deadlines will improve the delivery of information to investors and capital markets, assist in the efficient operation of the markets, while still allowing companies and their management adequate time to prepare and review their financial reports. We believe the accelerated deadlines will not have a significant adverse effect on either the accuracy or the cost of preparing the financial reports. Additionally, we believe the proposed criteria used to identify companies that will be subject to the accelerated reporting requirements are appropriate.
We also support the proposal that companies subject to the accelerated filing deadlines disclose in their annual reports where investors can obtain access to company Securities and Exchange Commission filings. We believe this will encourage additional use of the Internet which has proven to be an efficient means of distributing important information to investors in a cost effective and universal manner.
Please contact us if you desire further input or clarification at (248) 813-2592.
John G. Blahnik
Vice President and Treasurer,
Acting Chief Accounting Officer and Controller