May 22, 2002
Jonathan G. Katz, Secretary
United States Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
RE: File No. S7-08-02
Comments on Release No. 33-8089; 34-45741
Dear Mr. Katz:
CIGNA Corporation appreciates the opportunity to comment on the Commission's proposals to accelerate the filing dates of Forms 10-K and 10-Q and to require disclosure concerning website access to reports filed with the Commission. We are fully supportive of the Commission's efforts to improve the financial reporting process, and offer the following comments and suggestions on the proposals.
Over the past few years, CIGNA Corporation has undertaken to file its Forms 10-K and 10-Q earlier than it had historically. During the past two years, we filed our Forms 10-K within 67 days of year end, which was three to four weeks after the announcement of earnings. We filed our Forms 10-Q within 34 days of quarter end, which was within two days of announcing our earnings.
In order to file within the proposed 60 and 30 day limits, we would be required to accelerate our accounting closing and financial reporting processes. This would result in the need for a higher degree of estimation to be employed in the accounting closing process and in a reduction in the amount of time available at all levels to review and analyze information. Additionally, we are concerned that we will not have time for thoughtful analysis and review of our financial information in periods in which unusual transactions or circumstances arise, such as a major acquisition or divestiture. Accordingly, we respectfully request that the Commission adopt 70 and 35 days as the deadlines for filing Forms 10-K and 10-Q.
We are fully supportive of posting companies' reports on their websites. We believe that it makes sense for the posting requirement to be satisfied by a link to the EDGAR system. Accordingly, we encourage the Commission to take the steps necessary to make the EDGAR postings available immediately upon filing or, alternatively, to accept filings as timely notwithstanding the delay in the EDGAR system.
Should the Commission or its Staff have questions concerning the comments in this letter or desire additional information to assist it in preparing the adopting release, please do not hesitate to contact me at 215-761-2327.
Very truly yours,
/s/ James A. Sears
James A. Sears
Vice President and
Chief Accounting Officer