From: Brian Small
Sent: Wednesday, June 29, 2005
To: acspc@sec.gov
Subject: SOX 404 Extension


I listened to a portion of the webcast of your June 16th meeting. In the 22nd minute of the webcast, you begin a discussion of “considering extending the current moratorium that exists for very small companies” in issuing their SOX 404 certification. You mention that the issue will be brought to a vote in August. In the 25th minute of the webcast, it is mentioned that the one year delay is to “the first fiscal year ending after July 15, 2006”.

In March, the Commission extended the compliance date for non-accelerated filers to the first fiscal year ending on or after July 15, 2006.

The discussion left me confused about whether your committee will recommend an additional one-year extension. (to the first fiscal year ending on or after 7/15/07) I understand that the discussion mentioned only a recommendation and that the recommendation will not be voted upon until August. If possible, can you please clarify whether or not you expect to extend the deadline an additional year beyond the extension announced in March?

Thank you for your time and consideration.

Best Regards,
Brian Small
Director of Finance
Amtech Systems, Inc.