HUGHES, WATTERS & ASKANASE, L.L.P.
1415 LOUISIANA, 37TH FLOOR
HOUSTON, TEXAS 77002-7354
Telephone (713) 759-0818
Facsimile (713) 759-6834
May 22, 2002
Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549
RE: Comments regarding proposal S7-08-02 "Acceleration of Periodic Report Filing Dates and Disclosures Concerning Website Access to Reports"
Dear Mr. Katz,
I am writing in regard to the Securities and Exchange Commission proposal to shorten the filing times for 10-K and 10-Q periodic reports.
While I support the acceleration of the periodic report filing dates, I respectfully suggest that the new rules should be implemented with a longer transition time. However the matters with Arthur Andersen are ultimately resolved, the disruption to its clients, as well as the disruption that has been and will be caused at the remaining accounting firms, needs to be seriously considered by the Securities and Exchange Commission in the coming year. Further, a longer transition period would allow companies, audit committees, attorneys and auditors sufficient time to implement any new systems or procedures that are likely to develop this year to ensure their compliance with the shorter reporting periods. Additional transition time is particularly important in view of the proposed changes to Management's Disclosure and Analysis.
Thank you for your consideration of these comments.
Sincerely,
Adrienne Randle Bond, Of Counsel