Responses to ACSPC Request for Public Input

Disclosure System

Question 27. Will the phase-down to the final accelerated reporting deadlines for periodic reports under the 1934 Act for companies with $75 million market capitalization (ultimately 60 days for Form 10-K and 35 days for Form 10-Q) be burdensome for smaller companies? If so, please explain the manner and extent of this burden. Does the burden outweigh benefits to investors and markets for smaller companies?

The following answers have been received:

08/02/2005 13:57:44   Final accelerated reporting will indeed be burdensome for smaller companies.

08/02/2005 17:44:12   It the requirement for reporting were less than a reduction is days would be OK

08/03/2005 01:39:17   No. The advances in accounting systems and electronic reporting make it possible for companies to meet the accelerated reporting guidelines. Also, attention to accounting often helps management improve operating controls.

08/03/2005 08:55:04   Probably not

08/03/2005 08:58:39   All reporting is burdensome. WE just don't have the resources or manpower to do every thing.

08/03/2005 10:40:26   Yes. We barely have enough time to prepare the other reports required by the other regulatory bodies. Again, when you are dealing with the banking industry, we are under a lot more requirements than say a "small bicycle" company.

08/03/2005 12:17:58   yes burdesome. recommendation to small companies is to go to the londaon stock exchange and reduce costs and have true transparency and no naked shorting. dtcc doesnt exist there, which is a major problem in us markets for all companies, especially small ones

08/03/2005 15:01:40   No, We would feel comfortable in meeting the new timelines now even though we are at $33 million in market capitalization.

08/03/2005 15:22:49   We are exempt due to our market capitalization.

08/03/2005 16:58:51   We will need to change our processes. The tighter deadline will lead to some inefficiencies and overtime but we should be able to make this work.

08/03/2005 18:01:35   Please look into item no 29

08/03/2005 18:30:29   x

08/03/2005 19:54:33   I have no opinion on this question.

08/04/2005 09:39:15   Yes. It makes no sense that the SEC wants to increase quality of information but in the same breath they want to give companies and auditors less time to make sure it is correct. Small companies have very limited resources and tend to be the last clients their auditors give attention to.

08/04/2005 10:40:16   I think the phase down is burdensome to everyone. You want more accurate reporting and think you can get it by shortening the time to get the information together. Year ends are already so stressful with IRS reportings and other annual reporting requirements that shortening the time frame for anyone is probably unwarranted.

08/04/2005 12:09:05   Yes. See explanation in 26.

08/04/2005 13:38:24   Yes, smaller companies don't have the staffing.

08/04/2005 14:20:27   I will have our CFO give his opinion here.

08/04/2005 18:05:44   Yes. You want the information to be accurate.

08/05/2005 10:54:31   The burden is on accounting firms and finding the staff to comply with all of the SOX regs and still do the audit.

08/05/2005 12:44:28   I think this will be burdensome and will not benefit investors, as management spends increaing amounts of time complying with SOX versus building shareholder value.

08/05/2005 15:34:53   The timeline is extremely tight given all the reviews required by SOX. The benefit to the investors of lightly traded stock is very questionable.

08/05/2005 15:43:46   In all circumstances for small bank financial reporting it would be most beneficial for the SEC to consider use in some form of the Call Report to eliminate redundant reporting. If SEC and the FFIEC could talk to each other it would be one of the significant events ...

08/05/2005 16:45:38   Only if the above changes are not made. Paper is a usefull medium, but it is growing dated and is insecure and prone to destruction. Attempts to destory electronic bits of information are actually much harded than they appear. Data Recovery is an art form that shows that even burned, broken and smashed data devices can be recovered.

08/05/2005 19:33:08   It would be difficult to meet those deadlines for small companies under the existing regulations. Might be more practical if the auditors were allowed to help the company. This would reduce the rejections at the last minute by the auditors.

08/06/2005 13:52:06   Yes. It will be burdensome. Biggest problem is getting auditors finished on time.

08/08/2005 11:10:11   could be, it is usually just within the current deadline that all of the needed information can be gathered, assembled, drafted, reviewed and filed.

08/08/2005 11:39:29   This is huge. Small companies will either hire seasonal help at extremely high rates (not some college kid) or work their current staffs to death. In time, people will leave the profession in the same way that CPA firms have trouble maintaining experienced staff. Quality will then suffer.

08/08/2005 14:06:10   Yes it will be burdensome simply because they are always going to be pushed to get the reports out and that can lead to errors. Also you have the issue of auditor review and when are they going to get that work completed. If you want valid financial information you need to allow management and the auditors the time necessary to complete their work in an accurate manner. The investors can wait a few extra days. I don't see where it helps investors. There is a lot of work that goes into a quarterly report and with the our litigious environment, you are just inviting disaster if you make small companies have to comply with the accelerated filing deadlines.

08/08/2005 15:43:24   Yes. And for their accountants. With the 2 day requirements for 8-K filings of material events, I believe 40 days and 75 days are adequate.

08/08/2005 21:39:10   We don't believe that the phase-down to accelerated reporting will be overly burdensome for small companies, except for the issue of auditor resources. Given the current state of securities litigation, it is getting difficult to find auditors, especially for small companies. Auditors may not have the resources available to perform audits of many companies if their fiscal years are the same.

08/09/2005 09:30:31   Yes. Staff must stop other work to complete this timely.

08/09/2005 16:26:34   The obvious answer is yes...why do we need to accelerate this process...virtually everyone puts out press releases and has web casts...anyone not disclosing something significant and waiting for the 10-Q or 10-K will be punished by the market.

08/09/2005 17:25:10   Yes. Small companies have smaller accounting resources and need all the time presently allowed to do carefully prepared, meaningful reports. Investors can wait just as they do now.

08/10/2005 09:04:41   no comment

08/10/2005 13:44:39   Yes, We are pretty much at our external auditors mercy when it come to final review. As mentioned earlier our external firm has notified us they will no longer be doing audits of public companies, we'll have to find a different firm and we'll be low down on the totem pole, their review deadline could make things tight.

08/10/2005 16:00:18   Of course it will. We'll probably have to hire another accountant in order to get all the work done in a shorter period of time.

08/10/2005 17:18:15   Yes - very burdensome; tough to pull all info together, reviewed by management and auditors and counsel in a reasonable manner.

08/10/2005 22:09:27   All these reports take time and therefore addition personnel, therefore additional costs.

08/11/2005 20:27:22   It will be a disaster! We just exceed the treshold as an "Accelerated Filer" with revenues of $43M and the process took 5+ months and $500K. My views on the reduction in the time to file was covered above.

08/12/2005 13:12:10   No opinion.

08/12/2005 14:46:45   Not applicable

08/12/2005 16:35:01   As a non-listed company, it is unneccessary buden for us since investors receive no benefit.

08/13/2005 12:39:43   Don't know

08/15/2005 14:27:30   It certainly is burdensome and compliance depends primarily on two things: independent auditor availability and confidence that everyone understands the drill. Both of these were problems last year. Hopefully less so in the future.

08/15/2005 15:10:05   not sure

08/15/2005 15:13:01   Yes, these companies have smaller staffs and the 404 requirements are an additional burden. Don't forget that the resources at the auditing firms are being taxed here as well. They have fewer days to get meaninful reviews/audits completed. You can only push so far. I believe that there is significantly more risk in pushing audits from 90 days-to 75 days-to 60 days than there is with any other issue out there in the accounting world. Short audits truly scare me. I don't think the investors are really demanding this either. I know that they like earnings releases, maybe some additional safe harbor protections would assist with this.

08/15/2005 15:14:45   Absolutely. The staff support requirements for the short time period are a killer now, and this would require substantial temporary increases in professional staffing to get out a quality document. Otherwise, I would tend to go to a tabular format to decrease time required to put it together. I believe that the costs would outweigh the benefit.

08/15/2005 16:33:43   the Phase down will hurt us if we have to comply with 404, otherwise no. I would prefer the longer time frame- and frankly do not think that another week matters one way or another. If someone is going to be a crook, do you think another week is going to matter?

08/15/2005 16:41:14   Maybe. depends on whether they currently have accounting staff to meet the deadlines.

08/16/2005 09:51:21   No

08/16/2005 10:10:36   Yes. See answers above.

08/16/2005 10:21:17   No. No.

08/16/2005 10:26:28   not applicable

08/16/2005 10:44:16   No. See 17 above.

08/16/2005 11:18:54   It will be burdensome, especially considering the extent that auditors want to review filing now. For smaller companies with limited staff, there simply isn't enough time to get the books closed, prepare the filings and have them reviewed or audited in the shorter timeframe. As for benefits to investors and markets for smaller companies, the question assumes there are some. I question that and again would ask to see the evidence of such a statement.

08/16/2005 11:52:16   Yes. We have limited staff and any acceleration of filing requirements will knock us out of the box.

08/16/2005 12:15:34   Yes it will. We are a small company with one location. We are able to close our books in 2 business days and distribute financials to manangement for review. However, the time involved for auditor review, audit committee review, lawyer review and actual writing time, we are barely able to complete this process in 35 days today for quarterly reporting and 80-90 days for annual reporting.

08/16/2005 13:04:14   This requirement is not a burden for us.

08/16/2005 13:12:04   No matter the size of the company. 30-45 days should be enough for q's and 45 -60 should be OK for the K's.

08/16/2005 13:19:29   No opinion.

08/16/2005 13:20:23   It shouldn't be. They have had several years to prepare so if they are not ready it should tell you something about their commitment to it, and thier commitment to accounting and reporting matters. THere should be no excuses after 3 years.

08/16/2005 13:25:32   These will be burdensome, and will require additional staff and systems for compliance. It also compresses the time period for the Final Four to do their quarterly reviews, further diminishing the importance of small clients to the accounting hegemony (even companies with fiscal years tend to report on calendar quarters).

08/16/2005 13:27:00   The accelerated reporting is needed by investors and good companies will be able to meet the dates.

08/16/2005 14:08:05   This is a big problem. For example, some companies that report on sell-through accounting are reliant on their distributors for inventory and sales data. In extreme cases, that can take up to 15 days to collect, leaving less days to prepare for the filing deadline. Accelerating the deadline in that instance results in less days to review work and makes companies more prone to error.

08/16/2005 14:23:10   The accelerated reporting deadlines are burdensome for all companies. The 60 day requirement for the 10K is the most difficult issue. I recommend that companies be required to file an abbreviated set of financials including the income statement, balance sheet, and cash flow statement with limited footnote disclosure within 40 days of all quarters (including preliminary year-end at the time of the earnings release). The detailed footnote disclosures require significantly more work and it is extremely difficlut to prepare accurate detailed footnote disclosures, get the auditors to signoff, edgarize them and file within 60 days at year-end.

08/16/2005 14:54:27   Smaller companies generally have limited staff which makes reporting faster a challenge. At the same time the reporting burden has increased with SOX 404 as well as demands for more information. I think that the investors needs can be met while reducing the burden and cost to the company by eliminating or reducing required disclosures which are meaningless for a specific company.(This would require significant flexibility in GAAP and from the SEC)

08/16/2005 15:15:12   This regulation does not apply to our company; yet.

08/16/2005 16:08:50   While my company is a long way from being an accelerated filer, it would be burdensome on our organization to meet those requirements.

08/16/2005 16:16:04   I find this illogical in all respects. The SEC wants broader and more accurate disclosure in less time. I wonder how many controllers and CFO's were involved with this decision. Probably not many as it make no sense to me as a conservative CFO. It will only hasten financial results that are not as accurate.

08/16/2005 16:45:09   Yes! Given that the smaller companies must compete for the same auditor services as the larger companies, there must be longer filing dates for smaller companies. The 90 and 45 days has worked for all parties for decades. Why should one concluded now that those dates are today unacceptable?

08/16/2005 18:35:41   We will be challenged to meet these deadlines. I don't know whether the benefit will outweigh the burden.

08/16/2005 21:29:07   Uncertain.

08/17/2005 12:28:22   I don't think so.

08/17/2005 12:36:00   Yes--as mentioned before I am concerned with the increased demand on the time and attention of our experts that review these documents. It's likely that, given such restraints, the smaller companies will get handed to those who are less than expert.

08/17/2005 16:18:39   These companies will have the same or a heavier burden that we had as a company with a market capitalization of $125 million.

08/17/2005 18:49:20   Yes, i think smaller companies need more time and giving them the time will not create any significant negative impact on the markets or the shareholders.

08/17/2005 18:49:27   I don't think quicker reporting here helps anyone other than the auditors fee schedule. It is far more important that it is done right than speeded up.

08/17/2005 19:31:08   I think we can handle the reduced time frame. We are already performing better than the new requirements.

08/17/2005 21:27:12   Yes. It will require greater administrative resource, result in increased consulting expenses and provides little beneifit to the investing public. It is my opinion that the quarterly and annual filings have much less of an impact than the publication of quarterly earnings releases. I believe that the filings are important but could be greatly simplified (my guess is that about half of the information required by the 10K is not used and manybe not even read, by investors). I think the concept of accelerating the filings date is good but it needs to be accompanied by a goal towards reducing the size of the quarterly and annual filings by about half.

08/17/2005 22:55:14   Yes, these deadlines will be burdensome, since market cap has much less relevance than revenues in determining the size of a company's accounting staff and its spending on sophisticated IT systems to assist with reporting obligations. A $100 million revenue threshold for accelerated reporting would put the burden on companies better able to comply, without undue hardship.

08/18/2005 08:03:31   We support the fast reporting time because it benefits the management of a company and keeps the shareholders updated with actual information.

08/18/2005 14:30:38   Yes - Quality is more important than time. Shorter time only benefits short-term investors who speculate, not long-term investors.

08/19/2005 02:56:12   no effect. We've always had our Q ready to go in about 25 calendar days.

08/19/2005 11:44:44   If we have to meet the accelerated filers' deadlines, it would result in reduced quality. The turnaround time for compiling the information,review by auditors, final proofing and printing, etc is so tight as it is, that trying to go shorter would certainly result in errors, as well as consternation (and increased costs) by the auditors.

08/19/2005 13:49:01   For smaller companies, with limited resources (and some with limited IT resources) there could be extensive costs associated with the accelerated reporting deadlines. To meet the deadline will require the addition of more staff members to get the same amount of work completed in a shorter period of time; to do otherwise could sacrifice the quality of the data presentation.

08/19/2005 14:40:28   Definitely. At smaller public companies, the actual preparation of these documents is done by 2 - 3 people. Reducing the elapsed time to complete can only be accomplished with excessive overtime, leading to a higher probablilty of errors in financial reporting. i.e. an Accountant is usually not as clear-thinking when reviewing a final 10Q or 10K document at 1 a.m.!

08/19/2005 14:50:07   It would be a tremendous burden especially for community thrifts. As to the 10-Q, community thrifts also have to prepare several comprehensive reports for the Office of Thrift Supervision. The Thrift Financial Report is due by the end of the month following quarter-end. Schedule CMR is due 45 days after quarter-end.

08/19/2005 17:03:28   It may be a burden, but will be more useful to investors. Since the 10-Q needs to be filed anyway, this won't increase the workload, it will just accelerate it.

08/21/2005 04:46:26   No short deadlines are no problem. Most companies report earlier anyhow.

08/22/2005 14:21:23   In our case this could be a problem because a lot of our sales are overseas. As a result trying to get confirmations takes longer and it would be difficult to get everything done in 60 days.

08/22/2005 15:20:23   Yes, this will be burdensome and I don't think investors will be significantly better off getting the financial information sooner.

08/22/2005 15:47:02   No. Tigher deadlines are not a problem. In fact, larger companies need more time because they have multiple layers of consolidation. Small companies should be albe to report timely.

08/22/2005 15:47:34   Yes. It takes a certain number of hours to prepare the filings. If it has to be done in a shorter period of time, then that means more staff or more overtime. We can't afford to keep an extra staff person for quarterly reporting, so guess what that leaves as an option. Thanks, I have way too much free time on my hands.

08/22/2005 17:54:28   I don't think these deadlines should be a problem. I certainly want the information that quick, and it shouldn't be a problem to generate it.

08/22/2005 17:56:59   No. Timeliness is always a good thing, and provides a better window for the investor

08/22/2005 19:27:18   You wnat more accuracy in less time - that doesn't work. Extending the time would decompress the auditirs crucnh and give them more time to assists the small filers.

08/22/2005 20:10:17   I believe this will be very burdensome. I find our 6 accounts and attorney cannot get their schedules together for 45 day reporting. 35 days would be impossible. There are too many players in the loop at this point.

08/23/2005 15:56:30   No opinion

08/23/2005 16:06:08   I think it will be managable for the companies. I believe the CPA and securities attorney's will be hardest hit because they will need to pack a lot of work into a short time period. This time crunch will likely reduce the quality of their work.

08/23/2005 16:49:34   It could be due to manpower needs to meet deadlines.

08/23/2005 18:10:00   Absolutely. We are very concerned about further exacerbating spikes in staffing demand.

08/23/2005 21:11:03   Yes... the compression in filing can be achieved but only if/when the standardization of regulatory compliance and accounting requirements have been finalized. The compression in time should be delayed 2-3 years.

08/24/2005 12:24:07   this is probably ok, but requirements should be pared down for smaller companies.

08/24/2005 14:30:13   Yes, we don't have the resources/systems to be able to meet these deadlines today. In addition, it will be very difficult to get the auditors time scheduled to complete an audit in time to file, etc. You want accurate information and the current timing allows for everything to be as accurate as possible and bringing the dates forward creates an environment where more errors could occur due to the fast timing.

08/24/2005 16:19:27   It will. I just don't know how the auditing firms will get all thier work done in such a short window.

08/24/2005 16:26:56   Yes. Generally (and obviously) the finance and accounting staff in smaller companies is smaller than for larger companies, and their duties have increased in recent years. In addition, accounting firms have reduced their materiality thresholds, requiring a greater degree of accuracy in financial reporting, as regulations increase and timeframes shorten. We do not believe the acceleration of the reporting of financial statement information would not provide an advantage that outweighs the costs. Even without the accelerated reporting timeframes, other significant events must be disclosed promptly under current rules.

08/24/2005 16:54:47   yes, and outweighs benefits.

08/24/2005 20:16:09   Definately a burden. We are a small bank with one person doing the 10Q and 10K along with all the other duties of a bank CFO. We just do not have the staff to make it possible to meet these deadlines which means hiring more staff and that means more bottom line expense.

08/25/2005 15:23:41   Most definately, smaller companies do not have the staff or the technological advances that larger corporations have, to obtain immediate data is not possible. Therefore, smaller firms have to rely on more accruals and estimations which have higher risks related to them and less accurate data.

08/25/2005 16:04:36   Yes - it's burdensome for all, but the benefit outweighs the burden.

08/25/2005 16:26:29   Yes - this will be very burdensome. The audit fees will get more expensive as all audits and reporting will have to be done within the same time frame, so "discounts" for not be accelerated filers will go away. In addition, smaller companies do not have the interanl staffing to meet such quick deadlines.

08/25/2005 17:02:43   Yes. I do not believe the accelerated reporting deadlines have significantly improved financial reporting for accelerated filers and may indeed have hurt them. Smaller businesses are going to be even more burdened by such requirements.

08/26/2005 12:41:42   As an individual investor, the original timeframes were fine. Accelerating the filing process limits the amount of time that management, auditors and the audit committee have to review information or go back and gather more information. Ultimately, this is a detriment to investors.

08/26/2005 13:07:22   No Comment.

08/26/2005 15:31:29   The Accounting demands could result in additonal costs.

08/26/2005 16:22:08   Yes. With the requirements of new accounting standards it is not fair to reduce the time frames further.

08/26/2005 17:28:04   Yes it is a burden since individuals often have multiple responsibilities and the accelerated reporting can disrupt other functions without adding benefits to investors.

08/27/2005 11:21:03   Raise the $75 million market capitalization to $100 or $125 million, then you wouldn't be including smaller companies at all. Any accelerated reporting deadlines increase costs, because more people are required to do the accounting faster.

08/28/2005 23:37:43   10-Q reporting limits should remain at 45 days. Most small cap firms have one or at the most 2 FTE available to prepare these reports, along with other significant duties.

08/29/2005 07:07:37   No. Companies should be forced to report in a timely manner.

08/29/2005 10:21:15   While we are not yet at that market cap level, we do see accelerated deadlines being very burdensome for small companies, particularly those in heavily regulated industries like the insurance industry. For instance, we have state financial filings, on a statutory basis of accounting, that are due by the end of February and involve significant effort up to that time. We then use those same resources in March to do the SEC filing. This same situation exists on a quarterly basis to an extent with state and SEC filings. As such, a requirement to accelerate such deadlines with current resource levels would be detrimental to the goals of accuracy in such filings.

08/29/2005 10:21:25   While we are not yet at that market cap level, we do see accelerated deadlines being very burdensome for small companies, particularly those in heavily regulated industries like the insurance industry. For instance, we have state financial filings, on a statutory basis of accounting, that are due by the end of February and involve significant effort up to that time. We then use those same resources in March to do the SEC filing. This same situation exists on a quarterly basis to an extent with state and SEC filings. As such, a requirement to accelerate such deadlines with current resource levels would be detrimental to the goals of accuracy in such filings.

08/29/2005 11:21:29   Yes, the regulatory authorities are stressing accuracy more than ever, but they also want it faster. This gives us less time to complete more work with less resources devoted to completing the work.

08/29/2005 14:18:47   I think it will only be burdensome if they have not taken advantage of the extended grace period to implement systems in the hopes that lobbying efforts will entirely remove their need for compliance.

08/29/2005 14:53:30   Yes, and expensive. If so, please explain the manner and extent of this burden. To comply with the accelerated filing for 10-Ks within 60 days and 10-Qs within 35 days will add further to the unnecessary costs imposed on small companies. It is already difficult and expensive to complete these documents including cycling them through legal and the audit committee within the current 90 and 60 day respective requirements. Does the burden outweigh benefits to investors and markets for smaller companies? Although I am generally in favor of worthwhile information being published in a timely fashion; I believe that the stockholder who reads this level of detail will still be interested and informed if it is published a few days later.

08/29/2005 15:31:21   The accelerated filing dates could be a burden due to auditing firm review schedules. I do not feel that the accelerated filing dates provide any benefit to investors of small companies.

08/29/2005 16:20:53   Does not apply to us as we are under $75 million

08/29/2005 17:09:27   YES - it would be very burdensome for smaller companies with limited staff available to create these reports. The extra 15 to 30 days time is needed for the external audit and legal counsel reviews, as well as the EDGARizing and filing by a third party.

08/29/2005 17:12:26   Yes it would be because limited numbers of outside audit firms and legal firms would be trying to get the reviews done with the companies in a condensed time period for very little benefit (particularly small companies). I beleive the current 75/40 days should be made permanent and that "small business issuers" should stay at 90/45 days. They need more time due to the smaller internal resources. I also support the increase of accelerated issuers to 6% of market cap or about $700 million currently and also to raise the small business issuer to 1% of market cap or about $100 million currently.

08/29/2005 17:12:43   Yes. My company has just met the accelerated filer threshhold, due to our historically small public float. The accelerated filer threshhold is too low as we are no more able to handle the filing deadlines as we were before our stock price crept up. In larger companies, there is a dedicated staff to close the books, discuss issues, and complete the filings. In smaller companies, these are the same few individuals. With lower materiality threshholds, the auditors require more detailed information, as a few invoice may cause a material misstatement if not accounted for properly.

08/29/2005 17:36:32   Unable to comment

08/29/2005 19:02:32   Yes, you ask for more information and give less time to come up with it.

08/29/2005 19:05:24   The acceleration of reporting deadlines is burdensome. Given the preparation time and review requirements (management, audit committee, legal counsel, auditor), and given the difficulty of scheduling timely review by the outside audit partner and concurring partner who have competing demands with other client filings, the current deadline is a challenge. We believe that maintaining adequate preparation and review time is of more benefit to investors than the slight benefit provided by further acceleration of the filing deadlines.

08/29/2005 21:00:01   I don't think the timing is much of a burden.

08/29/2005 22:40:58   The accelerated reporting deadlines will be far more than burdensome, they could even result in such a rush to report that the information will have a higher probablity of error. This would defeat the benefit of reporting the financial information on an accelerated basis. Small companies will be required to increase thier staff to meet these deadlines, which will increase costs and decrease earnings per share to their investors. No benefit will be derived.

08/30/2005 15:04:16   No. Small companies as well as large companies must have their houses in order. Timely reporting is necessary and appropriate. The issue is what should be required in the reports. Streamlining and redundancy elimination should be a goal.

08/30/2005 15:07:00   Definitely burdensome. Smaller companies do not have the staff to be able to produce the vast amounts of information and disclosure required in order to meet these timeframes. The quality of the results are put in jeopardy when shortening the timeframe for review in smaller organizations.

08/30/2005 17:08:46   Yes, we believe that smaller public companies will incur significant burdens to comply with the ultimate accelerated filing requirements for Forms 10-K and 10-Q. Small companies generally have fewer people involved in the financial closing and reporting process. Smaller companies may have to invest in new systems and additional personnel to comply with the accelerated filing requirements and still ensure accurate financial reporting.

08/30/2005 18:26:14   The final accelerated reporting deadlines for periodic reports under the 1934 Act for companies with $75 million market capitalization are too short for smaller companies which do not have dedicated staff available to fulfill these requirements. Such shortened filing deadlines are not necessary for smaller companies where the investors tend to be long-term investors, not swayed on a day-to-day basis by company news and information.

08/30/2005 18:48:02   With all the new SOX requirements being implemented, this is a very unfortunate time to be accelerating the reporting deadlines. It is asking for trouble. Eventually I'm sure investors would like to see 60 days for form 10-K and this could be possible with ever-more-efficient computer procedures. The 35 days for Form 10-Q could also be met, especially if we have a change to only half-year reporting supplemented with very simplified quarterly reporting.

08/30/2005 18:51:48   The phase-down to the accelerated reporting deadlines will be extremely burdensome for smaller companies. For our company to meet the new deadlines, we would have to add additional accounting staff. We don´t believe that the benefit of the additional personnel would give us better information, just quicker information. To us, that burden would outweigh the benefit to investors. If the alternative of not adding people (having the existing number of people get the work done more quickly by working more hours per day) were selected, the likelihood of errors in the reports would increase.

08/30/2005 21:07:56   Yes, with limited staff in all areas of a small company, the filing deadlines are a distraction and put undue pressure to complete.

08/30/2005 21:39:41   Yes, it will be burdensome because it will increase costs for faster completion, and the auditing firms do not have the bandwidth to give smaller companies the priority needed to get Forms completed and filed in a timely manner.

08/30/2005 23:57:28   Yes. more accouting staffs need to employ to comply with that requirement to speed up the financial closing. More figure will be based on estimation because cost and expense is not finalized within a short period. Investors never mind to wait for 15 days for more accurate financials.

08/31/2005 08:31:59   This will be burdensome for all SEC companies. Tightening of the deadlines is asking for more errors. The SEC is requesting more disclosure from the corporations, more work from the independent auditors, all in a much tighter time frames. We all know that when you rush to get something done, there is a greater chance of error. The deadlines should not be shortened for any SEC filers.

08/31/2005 10:19:14   Yes, this will be burdensome to smaller companies due to their limited resources to produce these filings. I believe that smaller companies should continue to have more time to file their Form 10K filings and Form 10Q filings than the larger companies with over $75 million in market capitalization.

08/31/2005 10:21:37   Yes, but the benefit of disciplined reporting offsets the burden.

08/31/2005 14:00:12   The accelerated filer deadlines to be implemented in the future of 60 days/35 days seem innapropriate. The risks to acccuracy in requiring faster reporting do not appear to be worth the reward to investors of smaller companies. Smaller companies and their inveators would be better served by retaining the 90/45 day reporting periods.

08/31/2005 14:00:16   If the goal is to provide more accurate information to avoid further scandals, I don't see how accelerating reporting deadlines is going to help. This is a simple choice - are you willing to sacrifice some accuracy for more timely information? If so, then accelerated deadlines are not a problem. The problem comes in when companies have to sacrifice accuracy in order to meet the deadlines. Can't always have it both ways. Small companies don't have the staff to shorten the closing process enough to ensure accuracy in a shorter amount of time.

08/31/2005 14:25:37   Small companies will not be able to meet the new deadline without the extra help of outside accounting firms.

08/31/2005 14:32:46   It may create burden, but I'm not sure as to the extent. If the deadlines are shortened, you also have a shorter period to worry about subsequent events that may need to be disclosed. However, due to limited resources available to smaller companies, disclosures may suffer due to the accelerated filing dates. There may not be sufficent time to properly address issues that need disclosure, and the extent to which events are disclosed. Less substantive disclosure with greater emphasis on disclaimers may be the result for smaller companies.

08/31/2005 15:19:27   Yes, limited staff and less reliance of ERP systems will make it difficult to close the books, prepare the reports, and review the reports in a timely manner.

08/31/2005 16:13:45   The final accelerated reporting deadlines will be burdensome and more costly without significant increase in benefits to investors. The accelerated deadlines will be more costly for both the smaller companies and their auditors to file timely in a shorter period of time.

08/31/2005 16:16:33   27. We believe that the dollar threshold should be adjusted for inflation and current market conditions. The $75 million limit is too low. We suggest raising this limit to $1 billion, which would be much more meaningful and cost efficient.

08/31/2005 16:29:59   Faster filing for most small companies means more staff or consultants, thus more costs. It is one thing to arrive at the correct numbers and entirely something else to compile and file the various reports.

08/31/2005 17:16:33   What makes it burdensome is not the time. It is getting all the outside director's schedules to meet the time lines. They have other things going on and it's difficult for the company to come up with dates for all to meet and approve the press release and the 10Q

08/31/2005 18:22:30   The acceleration of due dates is very burdensome for smaller companies. We believe that an acceleration of due dates runs more risk of problems than the benefits it might bring. There are not as many investors looking at smaller company information, so far fewer investors would be affected by keeping the current time frames instead of the phase-down acceleration by 5 days. Acceleration is taking place when more demands are being placed on financial executives of smaller companies at year end. The Section 404 requirements have large year end activities for both testing and evaluations. In smaller companies, many of the same people perform financial report and internal control assessment functions. Continual acceleration, and the expiration of the exemptive order allowing smaller public companies additional time to complete internal control audits, creates a peak time problem that small companies can often solve only by adding personnel. Stopping the acceleration, and making the extended deadline for filing internal control reports permanent, would permit smaller public companies to meet their requirements while avoiding additional personnel costs. These delays will not create a burden to investors. Significant material events of interest to shareholders still must be reported in an 8-K filing.

08/31/2005 18:23:08   Yes, the accelerated deadlines are burdensome to smaller companies because the window to complete the reports is less but with the same amount of resources to accomplish the task, unless additional staff is hired, which is more costly. Yes, the burden outweighs the benefits because the investor would be getting the same information (and maybe not as good of information if the company does not have enough time to do analytics and research on issue), but now at an added cost to the company.

09/01/2005 00:55:31   Absolutely! Smaller companies don't necessarily have the depth or number of accounting personnel that larger companies do. The timing of filings creates much of the hardship in completing 10-Qs and 10-Ks currently. Accelerating these timelines will only put more strain on the accoutning personnel and systems and can actually increase risk of inaccuracies in financial data.

09/01/2005 11:40:19   I think these deadlines are challenging and allow less time to prepare complete documents for filing.

09/01/2005 14:30:54   Although our Company is less than $75 million in market cap, smaller companies generally have smaller accounting and finance departments, which the accelerated filings would become very prohibitive. In addition, accounting fees will be higher as more work will be performed on clients at concurrent times. Because of the 90 days filing requirement, smaller companies can wait to have audits conducted at a later date, when the accounting firms are less busy. With the large number of audits being performed by the Big 4 firms, larger audit fees have tricked down the second and third tier accounting firms.

09/01/2005 17:12:34   The burden out ways the benefit. You want quality information. Pushing the envelope from a time perspective can only harm that in a small company. Small companies have limited resources pushing the time up only causes potential quality problems.

09/04/2005 07:42:16   No. This deadline is required to support investors.

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