From: Max Crisp [MCRISP@stewart.com]
Sent: Friday, May 17, 2002 2:35 PM
To: 'rule-comments@sec.gov'
Subject: File No. S-7-08-02

Your proposal (S7-08-02)  will require us to file our Form 10Q with you
within 30 days following each quarter and our Form 10K within 45 days
following each year end. We respectively request you withdraw this proposal.


Instead, we suggest you set deadlines linked to the date of a company's
earnings press release.  We suggest you set deadlines at the earlier of (1)
15 days from the date of the quarterly press release and 30 days from the
date of the year end press release or (2) the current existing deadline. 

It is true in our case, and we believe for others, that the market place
demands we release earnings in the shortest time possible. We believe our
proposal will result in the optimum in timely information for a substantial
majority of companies. And this would be done without the undue burdens that
would be placed on companies under Proposal S7-08-02.

As a company with over 150 domestic and foreign subsidiaries to consolidate,
it takes all our resources working long hours to meet your current reporting
deadlines. While helpful, technology has not shortened many essential steps
required in producing meaningful and accurate financial statements. We need
time to internally review the financial statements from subsidiaries. Our
independent auditors and  audit committee also need review time.  Your
proposed deadlines will not provide adequate time to complete these reviews.

Along with shortening the time allowed for filings, you are also asking for
additional information to be reported and more involvement by management,
auditors and the audit committee. We do not believe the quality of
information can be maintained if your proposed deadlines become a
requirement.



Max Crisp					        E. Douglas Hodo, PhD
Executive Vice President			Director
Chief Financial Officer				Chairman of the Audit
Committee