From: Robert Krakauer [Robert.Krakauer@chippac.com]
Sent: Tuesday, April 30, 2002 10:36 AM
To: rule-comments@sec.gov
Subject: S7-08-02

	In regard to the Commissions proposals to accelerate the periodic
report filing dates for domestic issuers. 
	The proposals call for
	  
			o	Quarterly reports on Form 10-Q to be filed
within 30 calendar days after quarter end instead of the current 45 days;
and
			  
			o	Annual reports on Form 10-K to be filed
within 60 calendar days after fiscal year end instead of the current 90
days.

I have several concerns with the current proposal:

First, a shorter time period for filing is inconsistent with improved
quality of reporting, in my view.  At the same time as company's are
attempting to increase involvement, discussion and review of internal
controls and external reporting by and between external auditors, management
and audit committees this proposal would short the time available to
accomplish this improvement.  In my view, the improvement in timeliness
decreases the probability for improvements in quality of reporting and this
trade-off is not in the best interests of the investing public.

Secondly, this shorter time window will unfairly penalize the quality of
external auditor involvement, given a shorter window for their volume of
work to be complete for all their public companies who report.  This will
likely penalize smaller cap companies relative to larger cap companies.

Thirdly, if this change were to be enacted, I see no reasoning for a
disparate deadline between domestic filers and foreign filers, both of whom
are accessing the U.S. capital markets.  I would suggest that if a  change
is made, it should be made for both domestic and international filers
equally.

Robert Krakauer
Senior Vice President and Chief Financial Officer
ChipPAC Incorporated