March 21, 2005
Prior implementing the proposed securities reform, I believe the Division of Corporate Finance should implement a program which provides for uniformity in its comment process.
Currently, identical registration statements delivered to two offices of corporate finance will result in two different sets of comments. In some cases, two identical registration statements delivered to the same office of corporate finance will result in two different sets of comments.
I believe that until Corporate Finance, internally, implements uniformity in its comment process and publishes all of its internal written and unwritten policies, any proposed securities reform is without merit.