May 10, 2002
Jonathan Katz, Secretary
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549
Dear Secretary Katz:
We would like to take this opportunity to respond to the SEC proposal to shorten the deadlines for filing quarterly 10Q and annual 10K financial reports. We applaud the SEC for focusing on the timeliness of financial information reported to the public. However, we are concerned about the feasibility and potential ramifications of an acceleration of periodic reporting deadlines.
Our concerns about acceleration of reporting include:
1. The additional burden placed on our reporting process that are already requires us to file other regulatory reports 30 days after the end of a quarter.
2. The timeliness of having to meet the proposed new deadlines when additional third parties are involved in the review process before reports are filed such as independent auditors and attorneys. This would require us to have our reports available for these reviews in very short time frames, thereby possibly requiring estimates of certain financial data before the final information became available.
3. Difficulty in meeting time frames for printing and publishing annual reports that are subject to reviews by independent accountants and attorneys before they can be submitted to the printer. This could shorten the time frame from the current approximately 60 days in this process to as little as 40-45 days.
4. Accuracy of information to be included in financial statements due to certain subsidiary companys' ability to have this information available on a complete and timely basis. This would result in estimates in financial data that are less than accurate resulting in amending reports once the final data became available. This would not be in the best interests of shareholders who need accurate as well as timely information. We agree with our auditors proposed approach that financial reports be filed within a reasonably short time after a company's earnings announcements, but no later than existing SEC reporting deadlines.
Thank you for allowing us to voice our concerns on this very important issue.
Michael W. Helser