September 27, 2005
I wholeheartedly support the proposal to keep the 10-Q filing deadline for accelerated filers at 40 days.
I also believe that the 60-day filing deadline for Form 10-K is too short and request that the Commission consider keeping the deadline at 75 days, even for large accelerated filers.
If the Commission believes that 40 days is an acceptable deadline for Form 10-Qs, the Commission must also appreciate the fact that a Form 10-K takes more than 150 of the effort of a Form 10-Q. I believe that the quality of disclosures will suffer, that there will be increased likelihood of errors, and that the review process by management, independent public accounting firms and legal counsel will be unduly constrained by the 60-day deadline.
We do our best to prepare high-quality, accurate financial reports and will continue to do so. However, I fear that the shortened deadline for Form 10-K will create higher levels of stress and anxiety, adversely affecting the quality of life and quality of work of our financial reporting staff. It is my belief that the incremental value of the 60-day deadline is far outweighed by its risks and costs.
I would appreciate your consideration of expanding the subject proposal to also eliminate the 60-day deadline for filing of 10-Ks, leaving the deadline at 75 days.