File No. S7-40-02From: Tomes, Kenda [KTomes@stinsonmoheck.com]
Sent: Wednesday, November 06, 2002 9:30 AM
To: 'rule-comments@sec.gov'
Subject: File No. S7-40-02

The financial expert and code of ethics rules are unclear as to when the 
will be required.  Will there be a transition period to allow companies to 
find financial experts and implement codes.  If not what is the cut off date 
for providing required disclosure, for example annual reports covering fiscal 
years which end after 1/26/02?

Kenda K. Tomes 
Stinson Morrison Hecker LLP 
2600 Grand Avenue 
Kansas City, Missouri 64108 
816-691-2419 (direct) 
816-474-4208 (fax)