Unassociated Document
FROMEX
EQUITY CORP
320
Manville Road
Pleasantville,
N. Y. 10570
Tel:
(914) 632-6730
September
25, 2007
Ms.
Jessica Barberich
Staff
Accountant
Securities
& Exchange Commission
Division
of Corporation Finance
Washington,
D. C. 20549
Mail
Stop
4561
Tel:
(202) 551-3782
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Reply
to your letter of
9/18/07
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Dear
Ms.
Barberich:
We
propose to add the underlined text to the last paragraph of the Explanatory
Note
and page 10:
“The
officers of the Company have reconsidered the effectiveness of its disclosure
controls and procedures as of November 30, 2006 in the light of the restatement
described above and have concluded that the Company’s disclosure controls and
procedures were not effective as of November 30, 2006 with
respect to a transaction not in the ordinary course of business, namely a
transfer of assets between entities under common control. Upon such assessment
the Company corrected its procedures to provide for a closer monitoring of
such
transactions to be sure that the correct accounting guidelines are applied.
This
improved its disclosure controls and procedures
so that
they were effective when the financial statements were restated in Form 10
on
May 14, 2007 and as of the date of the 10Q/A Amendment No. 1. The officers
have
addressed this reconsideration and evaluation in their certifications in
Exhibits 31.1 and 31.2 at pages 23 and 24 of this Amendment.”
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Sincerely,
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/s/Steven
Bregman
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Steven
Bregman, President
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Chief
Financial Officer
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