GREAT AMERICAN FINANCIAL RESOURCES, INC.
250 EAST FIFTH STREET
CINCINNATI, OHIO 45202
May 23, 2002
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street
Washington, DC 20549
Re: File No.S7-08-02
Dear Mr. Katz,
Great American Financial Resources (GAFRI) opposes the Commission's proposal to accelerate the periodic report filing dates for several reasons.
We agree that technological advances have made it easier to process information over the last 30 years. However, it is important to note that even though our current staffing levels are designed to meet the additional disclosure and review requirements established over the same time period, preparation of the periodic reports still requires very long hours during the year end and quarterly "busy seasons" to meet the current filing dates. To accelerate the periodic report filing dates would require additional staffing, costing us probably several hundred thousand dollars, and leaving us overstaffed for the "non-busy seasons."
Additionally, GAFRI's insurance subsidiaries must file separate annual and quarterly financial statements (prepared on a statutory accounting basis) with state regulatory authorities in roughly the same timeframe as the SEC's proposals, while simultaneously providing GAAP financial data for consolidation into GAFRI's filings. Accelerating the SEC filing deadlines will likely add the same staffing issues as above for our larger insurance subsidiaries.
Finally, because of the time constraints of compiling the required financial information, GAFRI has not released earnings significantly in advance of current SEC filing deadlines. In fact, it's not unusual for our earnings releases to go out after the proposed accelerated deadlines. As you know, significant S-K, M, D & A, and footnote disclosures must be prepared above and beyond the information in our earnings releases prior to filing our 10-K and 10-Q's, which obviously makes compliance with the new deadlines problematic.
GAFRI will have significant problems meeting the accelerated filing deadlines. The reliability and accuracy of reports filed by registered issuers may suffer as a result of shortened due dates. In this respect, we believe accelerated filing deadlines will actually work against the Commission's desire of improving the quality of periodic disclosure. Any possible advantage, for example, of having a Form 10-Q filed 15 days earlier will be lost if the content of that filing is less informative and reliable, which will likely result from the shortening of the filing deadlines.
Christopher P. Miliano
Chief Financial Officer
Great American Financial Resources, Inc.