May 22, 2002
File No. S7-08-02
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 North Fifth Street NW
Washington DC 20549
To The Securities and Exchange Commission
I favor the acceleration of reporting dates for public companies as proposed.
My view is based on over 30 years of experience as both an auditor and preparer of financial statements and SEC filings. In addition, I spent 10 years assisting in the formulation of Generally Accepted Accounting Principles.
When I began working for a major public company as manager of published reports and SEC filings, a career that spanned 20 years, the SEC had adopted the recommendations of the Wheat Report. Among those recommendations was that public companies should be required to file their Annual Form 10-K within 90 days instead of 120 days of the end of their fiscal year, although the required financial schedules could still be filed within the longer period.
At that time, our diversified multi-national company had 250 reporting units throughout the world. The primary reporting was by Telexes (remember them), which were entered into the central mainframe computer at world headquarters. Tab runs were produced which were further processed by a staff of 10 consolidation accountants using pencils, paper, adding machines and calculators. Not only were the basic financial statements prepared in that manner, but additionally so were all the statistics needed for notes to the financial statements, schedules and other annual report data, such as employment figures etc. The next step was for the independent auditors to do their job. (Ours were Arthur Andersen, the gold standard among the then Big 8.)
We worked to seven or later every night and every Saturday from January through the middle of March.
Nowadays we have personal computers and I daresay that staff of 10 has been reduced significantly without any impairment in the quality of the product; indeed the speed of completion in comparison with 30 years ago must be awesome.
Accordingly, the proposed modest acceleration in filing dates appear reasonable to this codger.
Al Goll, CPA