From: Roger Mandery [Roger.Mandery@firstmutual.com]
Sent: Saturday, April 27, 2002 1:44 PM
To: Rule-comments@sec.gov
Cc: Kari Stenslie; John Valaas
Subject: File No. S-08-02

I would like to express my serious concerns to the proposed rule that would accelerate the 
filing dates of Forms 10-K and 10-Q. We are a small bank with a market cap that ranges from 
70-80 million. We have a small accounting department that can barely get the 10K and 10Q 
documents out on time within the current limitations. Because of the complexity of the MD&A 
its not possible to hire another accounting clerk and delegate that task. The Controller and 
I are responsible for the treasury, accounting, budgeting, cost accounting, internal control, 
and investor relations functions. It's not realistic to significantly shorten the 10K and 10Q 
reporting times and expect that the two of us can prepare those documents in the appropriate 
manner.

I urge you not to adopt the proposed accelerated filing deadlines.

Roger A. Mandery
CFO
First Mutual Bancshares