-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, KikCPLp4jnbS4uf8+XuPFN8aHYqf8+lHKQPhlK/x8O2bmw5KHd0lZ2HSq0Ohjbe+ 7VlkmmLR0sevMS5nM0yPKw== 0000000000-06-003550.txt : 20070514 0000000000-06-003550.hdr.sgml : 20070514 20060123150110 ACCESSION NUMBER: 0000000000-06-003550 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060123 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: MORGAN STANLEY CENTRAL INDEX KEY: 0000895421 STANDARD INDUSTRIAL CLASSIFICATION: SECURITY BROKERS, DEALERS & FLOTATION COMPANIES [6211] IRS NUMBER: 363145972 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 1585 BROADWAY CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212-761-4000 MAIL ADDRESS: STREET 1: 1585 BROADWAY CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER & CO DATE OF NAME CHANGE: 19980326 FORMER COMPANY: FORMER CONFORMED NAME: DEAN WITTER DISCOVER & CO DATE OF NAME CHANGE: 19960315 LETTER 1 filename1.txt Mail Stop 4561 January 23, 2006 David H. Sidwell Chief Financial Officer Morgan Stanley 1585 Broadway New York, New York 10036 RE: Morgan Stanley Form 10-K for Fiscal Year Ended November 30, 2004 Filed February 11, 2005 File No. 001-11758 Dear Mr. Sidwell, We have reviewed your letter filed on January 12, 2006 and have the following comment. Please provide us with the requested information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Management`s Discussion and Analysis of Financial Condition and Results of Operations Critical Accounting Policies Fair Value, page 61 1. We note your response to comment 1 from our letter dated December 15, 2005 that you apply the AICPA Broker-Dealer Guide to your activities unless other specialized industry guidance, including AICPA Audit Guides, is required to be applied to the operation of an individual subsidiary. Please tell us all the types of positions, aside from securities and derivatives that you account for at fair value as inventory under the AICPA Broker-Dealer Guide. Please indicate the specific nature of each type of financial and non- financial position that you fair value and explain your basis for applying fair value accounting Please respond to this comment within 10 business days or tell us when you will provide us with a response. Your letter should key your response to our comment and provide any requested information. Please file your letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. You may contact Michael Volley, Staff Accountant, at (202) 551- 3437 or me at (202) 551-3490 if you have questions regarding our comment. Sincerely, Don Walker Senior Assistant Chief Accountant ?? ?? ?? ?? David H. Sidwell Morgan Stanley January 23, 2006 Page 2 -----END PRIVACY-ENHANCED MESSAGE-----