TO: Files
FROM: J. Minke-Girard
RE: Release Nos. 33-8098; 34-45907; International Series Release No. 1258
File No. S7-16-02
DATE: July 12, 2002

On April 1, 2002, Bob Herdman (Chief Accountant) and other members of the Office of Chief Accountant and Division of Corporation Finance staff met with representatives of the Committee on Corporate Reporting (CCR) of Financial Executives International (FEI). During the meeting, SEC staff indicated that the Commission is in the process of considering proposed rules that would call for improved disclosure in Management's Discussion and Analysis (MD&A) about companies' critical accounting estimates. Members of the CCR were generally supportive of the initiative but cautioned the staff against detailed requirements in new rules and expressed the need for more "safe harbors" related to MD&A disclosure. The CCR also provided the following specific comments: