Diamond Offshore Drilling
May 22, 2002
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Re: File No. S7-08-02
Dear Mr. Katz:
Diamond Offshore Drilling, Inc. is a public company traded on the New York Stock Exchange with public float in excess of $75 million. We, as the Chief Financial Officer and Controller of Diamond Offshore Drilling, Inc., wish to express the company's opposition to the proposal to accelerate the filing due dates for quarterly and annual reports.
While it is true that there have been advances in communication and information technology since the initial adoption of the due dates for the filing of quarterly and annual reports with the Securities and Exchange Commission, it is also true that the volume and complexity of the required disclosure in those reports has burgeoned.
At Diamond Offshore Drilling, a company with offices around the world, the books are typically closed by the eighth working day of each month. The process of preparing the Form 10-Qs and Form 10-Ks subsequent to the close of the books at each quarter end involves compilation of the financial statements including footnotes and drafting of disclosure required by S-X and S-K regulations. The company's management, external auditors, inside legal counsel, outside legal counsel and the Audit Committee then review the initial draft. There are generally multiple revisions resulting from the review. Once the draft becomes final it must be converted into EDGAR format to be filed. The proposed accelerated due dates for the filing of the Form 10Qs and Form 10Ks do not allow enough time to complete this preparation process under the current closing schedule.
If the proposed accelerated due dates are put into place the books of the company will need to be closed earlier in the month. An earlier close will require a greater use of estimates and could impair the integrity of the financial information presented. The reliability and accuracy of the financial statements will be greater if the existing due dates are left intact.
Gary T. Krenek
Vice President & Chief Financial Officer
Beth G. Gordon
Controller and Chief Accounting Officer