From: jhurlbutt@stepan.com
Sent: Tuesday, May 14, 2002 12:55 PM
To: rule-comments@sec.gov
Subject: File No. S7-08-02 Proposed Acceleration of Filing Dates

Jonathon G. Katz
Secretary, Securities and Exchange Commission
450 Fifth NW
Washington  D.C. 20549

In response to your request for comments on the acceleration of filing
dates,  I am vigorously opposed. The loss of trust in financial reporting
in the U.S. is due to poor quality and integrity of a few filing entities
rather than the timeliness of the overall reporting population. We should
place our regulatory efforts into fixing that which is broken rather than
penalizing the companies who have set high qualitative standards which will
only be sacrificed by the rush to meet earlier deadlines that hinder the
company, their auditor and audit committee from fulfilling their
responsibilities.

Timely communication of significant information has been and should
continue to be required by way of  Form 8K.

The larger problem is qualitative. It is time to get government and
industry back to the basics of eliminating the use of abusive accounting
practices. Earlier reporting deadlines are of little benefit when filings
are subsequently restated!

James E. Hurlbutt
Vice President and Corporate Controller
Stepan Company