May 22, 2002
Jonathan G. Katz
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
|Re:||File No. S7-08-02|
Acceleration of Periodic Report Filing Dates and Disclosure Concerning
Website Access to Reports
Dear Mr. Katz:
Wells Fargo & Company submits the following comments for your consideration in response to the Commission's proposal to accelerate the due dates for quarterly reports on Form 10-Q to within 30 days after quarter end and for annual reports on Form 10-K to within 60 days after year end.
Form 10-Q. We recommend that the due dates for reports on Form 10-Q be accelerated to 40 days after quarter end instead of the proposed 30 days. Our reports on Form 10-Q are subject to a number of levels of analysis, review and verification, not only within our controller's division, but also among senior management, legal counsel and independent auditors. We acknowledge there have been significant technological advances in the last 30 years, however the time gained from these advances has been offset by increased complexity of reporting requirements over the same time period. The time required for meaningful analysis, review and verification has not decreased. We believe the benefit to investors of receiving the report 10 days earlier is outweighed by the risk that they might receive information that has not received the same degree of analysis, review and verification that a 40-day period would permit.
Form 10-K. We concur with the Commission's proposal to accelerate the due dates for annual reports on Form 10-K to within 60 days after the year end.
We appreciate the opportunity to comment on the proposals. If you have any questions about our comments, please call me at (415) 396-8512, or Alison Becker, Manager of SEC Reporting at (415) 396-2546.
Les L. Quock
Senior Vice President & Controller