Comments on Proposed Rule: Disclosure in Management's Discussion and Analysis about the Application of Critical Accounting Policies Securities and Exchange Commission

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from Jenifer Minke-Girard regarding November 5, 2002 meeting with the Accounting Committee of the American Bankers Association and Commission staff
Public Comment Kurt Pfotenhauer, Senior Vice President-Government Affairs, Mortgage Bankers Association of America
Public Comment Joseph A. Grundfest, William A. Franke Professor of Law and Business, Stanford Law School, et al.
Public Comment Sarah G. Smith, Chief Accounting Officer, Goldman Sachs Group, Inc., New York, N.Y.
Public Comment Marc E. Lackritz, President, Securities Industry Association
Public Comment Joseph A. Grundfest, William A. Franke Professor of Law and Business, Stanford Law School, Stanford, Calif.
Public Comment Ashwinpaul C. Sondhi, Ph.D., Chair, Financial Accounting Policy Committee; Nazir S. Rahemtulla, CFA, Associate, Advocacy, AIMR, Association for Investment Management and Research
Public Comment Cleary, Gottlieb, Steen & Hamilton
Public Comment Joseph L. Sclafani, Executive Vice President & Controller, J.P. Morgan Chase & Co., New York, N.Y.
Public Comment Gregory W. Norwood, Bank of America Corporation
Public Comment Henry B. Schram, Senior Vice President and Chief Accounting Officer, The Chubb Corporation
Public Comment John Fosina, First Vice President, Corporate Controller, and Esther Mills, First Vice President, Accounting Policy, Merrill Lynch, New York, N.Y.
Public Comment Gerald S. Backman, Chairman of the Committee, Committee on Securities Regulation, Business Law Section, New York State Bar Association
Public Comment Jeffrey P. Neubert, President and Chief Executive Officer, New York Clearing House Association L.L.C
Public Comment Ernst & Young LLP
Public Comment Broc Romanek, Chair of Subcommittee on Critical Accounting Policy Disclosures, American Society of Corporate Secretaries
Public Comment Karen L. Barr, General Counsel, Investment Counsel Association of America
Meeting with SEC Officials Memorandum from Eric Schuppenhauer regarding July 10, 2002 SEC staff meeting with the Accounting Committee of the American Bankers Association
Public Comment Stanley Keller, Chair - Committee on Federal Regulation of Securities; Richard H. Rowe, Chair - Committee on Law and Accounting, Committee on Federal Regulation of Securities and the Committee on Law and Accounting, Section of Business Law of the American Bar Association
Public Comment Rajeev Bhalla, Vice President and Controller, Lockheed Martin Corporation
Public Comment Alvin C. Rodack, CCM, Associate Treasurer, Ohio State University, Chairman, AFP Government Relations Committee; James R. Haddad, CCM, Vice President, Corporate Finance, Cadence Design Systems, Inc., Chairman, AFP Finacial Accounting and Investor Relations Task Force, Association for Financial Professionals
Public Comment Andy D. Bryant, Executive Vice President, Chief Financial and Enterprise Services Officer, Intel Corporation
Public Comment Angela Seeley, Financial Reporting - CVPS
Public Comment Arnold C. Hanish, Executive Director, Finance and Chief Accounting Officer, Eli Lilly and Company, Indianapolis, Ind.
Public Comment Billie K. Rawot, Vice President & Controller, Eaton Corporation
Public Comment Bob Laux, Director, External Reporting, Microsoft Corporation
Public Comment Charlotte M. Bahin, Director of Regulatory Affairs, Senior Regulatory Counsel, America's Community Bankers
Public Comment Deloitte & Touche
Public Comment E. Follin Smith, Senior Vice President and the Chief Financial Officer of Constellation Energy Group, Inc.
Public Comment Gary Belitz, Controller and Chief Accounting Officer, Williams Companies, Inc.

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-16-02
Release Number
33-8098
34-45907
IS-1258
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