-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, EZk0U53q5unhv8NFCESgQ7rrsm+2aJIbep57eSN7+kiTydBpUqdj4QSeCmjPjKOw 8m4rr2wW06kSR46T5iZ47g== 0000000000-05-041868.txt : 20061005 0000000000-05-041868.hdr.sgml : 20061005 20050812161945 ACCESSION NUMBER: 0000000000-05-041868 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050812 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: COLLINS INDUSTRIES INC CENTRAL INDEX KEY: 0000021759 STANDARD INDUSTRIAL CLASSIFICATION: MOTOR VEHICLES & PASSENGER CAR BODIES [3711] IRS NUMBER: 430985160 STATE OF INCORPORATION: MO FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 15 COMPOUND DR CITY: HUTCHINSON STATE: KS ZIP: 67502 BUSINESS PHONE: 6206635551 MAIL ADDRESS: STREET 1: 15 COMPOUND DRIVE STREET 2: PO BOX 648 CITY: HUTCHINSON STATE: KS ZIP: 67502 LETTER 1 filename1.txt Mail Stop 3561 August 12, 2005 BY U.S. MAIL and FACSIMILE [ (817) 310 - 0907 ] Mr. Cletus C. Glasener Chief Financial Officer COLLINS INDUSTRIES, INC. 15 Compound Drive, Hutchinson, Kansas 67502 Re: Collins Industries, Inc. Item 4.01 Form 8-K Filed August 9, 2005 File No. 0-32369 Dear Mr. Glasener: We have reviewed the above referenced filing and have the following comments which request certain supplemental information. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not raise additional comments. Pursuant to Rule 101(a)(3) of Regulation S-T, your response should be submitted via EDGAR, under the label "corresp," within five business days of the date of this letter. Please note that if you require longer than five business days to respond, you should contact the staff immediately to request additional time. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Cletus C. Glasener Collins Industries, Inc. August 12, 2005 Page 2 Item 4.01 of Form 8-K Reportable Condition: Material Internal Control Weaknesses 1. See the fourth paragraph regarding the disclosure of material weaknesses in your internal controls. Please provide us with a copy of any letters or written communication to and from the former accountants, KPMG LLP, to management, the Board of Directors or the audit committee regarding the material weaknesses in your internal controls. 2. In detail, describe for us the nature of each material weakness in internal controls cited by the former auditors and the amounts involved, if any. Also, tell us in what period the reportable event occurred and whether or not you restated (or intend to restate) any prior period for any adjustment resulting from the reportable event; and if not, why not. Tell us in detail the steps you have taken (or plan to take) and procedures you implemented (or plan to implement) to correct each reportable event. 3. Please provide us with a schedule of your fiscal year end October 31, 2004 fourth quarter adjustments recorded in connection with or as a result of the audit. Clearly explain the reason for each adjustment. For each adjustment, show us the impact on pre-tax net loss. Quantify the net effect of all adjustments on pre-tax net income (loss). Also, tell us if any of the adjustments relate to a prior period. Explain in detail why you believe the timing of each adjustment is appropriate. Other We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: Cletus C. Glasener Collins Industries, Inc. August 12, 2005 Page 3 * the company is responsible for the adequacy and accuracy of the disclosure in the filing; * staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and * the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. Closing You may contact the undersigned below at (202) 551-3328, or in her absence to Mr. Robert Benton, Senior Staff Accountant, at (202) 551-3804, if you have questions regarding the above matters. Sincerely, Beverly A. Singleton Staff Accountant ?? (..continued) -----END PRIVACY-ENHANCED MESSAGE-----