From: Tim Okeefe [tokeef@attbi.com] Sent: Thursday, November 07, 2002 10:32 AM To: rule-comments@sec.gov Subject: FILE NO. S7-42-02 - Off-Balance Sheet Disclosure: Require Disclosure Dear SEC Reviewer: Please do your job and require publicly traded entities to disclose material items affecting the economic and financial condition of the company, including off-balance sheet arrangements. Timothy O'Keefe, Economist and Investor DISCLOSURE IN MANAGEMENT'S DISCUSSION AND ANALYSIS ABOUT OFF-BALANCE SHEET ARRANGEMENTS, CONTRACTUAL OBLIGATIONS AND CONTINGENT LIABILITIES AND COMMITMENTS 17 CFR Parts 228, 229 and 249 RELEASE NOS. 33-8144; 34-46767 INTERNATIONAL SERIES RELEASE NO. 1264 FILE NO. S7-42-02 RIN 3235-AI70 Tim