Bernard E. Klein
3000 Stirling Road
Hollywood, FL 33021
954-981-8800 Fax 954-981-8800
August 2, 2002
Page 1 of 1
Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission rule-comments@sec.gov
450 Fifth Street, NW
Washington, DC 20549-0609
Re: File No. S7-21-02
Certification Of Disclosure In Companies' Quarterly And Annual Reports
Dear Mr. Katz:
In reviewing the earlier requirement for 947 companies to certify past filings, it seems that the SEC posted the format for Exhibit A required by Rule 4-460 at http://www.sec.gov/rules/other/4-460a.htm in a format that most companies would choose to modify.
In the Paperwork Reduction Act Disclosure portion of that document, the SEC estimate[d] that providing the requested information will take, on average, approximately 25 hours.
If this type of requirement is now going to be required for all 10-K, 10-KSB, 10-Q, 10-QSB, and 20-F and 40-F filers, could you post on the edgarfiling site, or otherwise, a Word-formatted version, generally as usable as the EDGAR Filer Manual, and knock a few minutes off the time?
Thank you.
Sincerely,
/s/ Bernard E Klein
Bernard E Klein
President