To : Commission File No. S7-08-02
From : Jeffrey J. Minton
Special Counsel
Office of Rulemaking
Division of Corporation Finance
U.S. Securities and Exchange Commission
Re : Acceleration of Periodic Reporting Filing Dates and Disclosure Concerning Website Access to Reports, Release Nos. 33-8989; 34-35741

Date :

June 7, 2002


From 10:00 a.m. to 12:00 noon on June 7, 2002, Chairman Pitt, Commissioner Glassman, members of the Division of Corporation Finance, the Office of Economic Analysis and the Division of Enforcement met with a large delegation of the American Society of Corporate Secretaries. To comply with Sunshine Act requirements, only one Commissioner was present at any given time. Chairman Pitt gave opening remarks and left at approximately 10:15 a.m. Commissioner Glassman joined the meeting at approximately 11:00 a.m. and remained for the remainder of the meeting. The ASCS delegation included Pauline Candaux, Susan Ellen Wolf, Alan Dye, Broc Romanek, Judy Witterschein, Kathy Gibson, Carol Ward, David Smith and Bob Lamm. Matters discussed included the ASCS comment letter on the acceleration and website proposals, themes from other comment letters received, the critical accounting estimates proposal and other rulemaking initiatives.

Pauline Candaux provided a summary of the ASCS comment letter, including the results of the ASCS survey and the need for a lengthy transition period. In addition, ASCS representatives mentioned a couple of additional points not mentioned in their comment letter: