File No. S7-08-02From: Cyndi Miller [Cynthia.Miller@efi.com]
Sent: Thursday, April 25, 2002 7:05 PM
To: 'rule-comments@sec.gov'
Subject: File No. S7-08-02

Comments  to File No. S7-08-02 

Dear Sirs: 

As a Financial Reporting Manager, I find your proposed acceleration of filing to be in 
opposition to providing investors with complete and accurate filings. While most audits and 
reviews are completed before the filing deadlines you propose, the process of preparing the 
SEC documents are not.  The financial statements are only a part of what needs to be prepared.  
To properly prepare the MD&A section takes additional time.  The SEC has recently stressed 
the need to not use boilerplate in this section.  Preparation in the time-frame being proposed 
would mean that parts of this section would be written before the reporting period was ended.  
Early preparation does not allow for a complete evaluation of the information used to prepare 
this section. Once completed, the document must be reviewed, not only within the organization preparing the documents, but by the chosen auditing firm and by legal counsel.  Rushing through 
this process will not enhance the information given to the investors.  The adage "Haste makes 
waste" comes to mind.  

I have one quick comment in response to your second proposal requiring companies subject to the accelerated filing deadlines to have their reports on-line on their Internet web-site the same 
day as they file.  If the SEC cannot have the day's filings available immediately, why do you 
expect that the filer would be able to have it available immediately?  Many companies use outside services to maintain their web-sites.  If they furnish a copy of their filing to those services 
at the same time that they file, there may be a 24-hour delay before it can be placed on the web-site.  In some cases, it may be longer.  And while we like to think that all SEC regulated companies would have a web-site, there may be some that do not.  Will you require them to 
establish a web-site to publish a document that can be obtained from the SEC EDGAR archives?

I find your proposed ruling a quick response to a very bad situation, with little thought 
given to whether the ruling will truly add anything of value for investors.

Cyndi Miller 
Financial Reporting Manager 
Electronics for Imaging, Inc.