Rule 33-8090 : Good Ideas, what about SPEs?From: Kevin J. Rice [kevin@justanyone.com]
Sent: Sunday, June 16, 2002 6:17 PM
To: rule-comments@sec.gov
Subject: Rule 33-8090 : Good Ideas, what about SPEs? (S7-09-02)

Hello: 

I'd like to comment on rule 33-8090. 

I approve of the tightening of the rules as specified in your summary document 
posted on the SEC website. 

I'm wondering if it goes far enough to reform off-balance sheet activity such as 
Enron's Special Purpose Entities, or SPE's, as well as those of companies like GE.  
This activity seriously affects a company's material well-being.  Yes, it is covered 
under one of your general rules, that companies must specify in the 8-K that there 
are debts and obligations, but this may not be explicit enough to bring out all the 
other companies who are doing similar things to Enron and GE.

I would like to express my support for the rule 33-8090.  I would also like to 
support further changes to bring U.S. GAAP in line with International accounting 
standards, including the specification that all SPEs that a company / corporation 
owns, has partnerships in, etc., are disclosed to the public in a special SEC or 
other filing, and the 'dollars at risk' (banks use this measurement) is placed in 
the quarterly and annual reports.

Thank you for your time, 
Most Cordially Yours, 
-- Kevin Rice 

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Kevin J. Rice 
Senior Software Engineer 
1136 Lockwood Ct. W., Buffalo Grove IL 60089 
Homepage: http://www.JustAnyone.com 
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