January 12, 2009 | Phillip A. Reinsch Executive Vice President and Chief Financial Officer |
Re: | Capstead Mortgage Corporation (the “Company”) Form 10-K for the year ended December 31, 2007 File No. 001-08896 |
1. | We read your response to comment one. As discussed, the calculation of net interest margin of mortgage securities and similar investments on your Statements of Income should include interest expense on unsecured borrowings. Please amend your Form 10-K for the year ended December 31, 2007 and the subsequently filed Forms 10-Q to comply with this presentation. | |
In response to your request, on January 12, 2009 we filed an amended and restated 2007 Form 10-K and Form 10-Q/As for 2008. |
2. | Further to our comment, please also file your required Item 4.02 8-K. The 8-K should include the date of the conclusion regarding non-reliance, the financial statement years and periods that should no longer be relied upon, a brief description of the facts underlying your conclusion, a statement whether your audit committee or its alternative has discussed this matter with your independent accountants, your time frame for filing the restated financial statements, and describe how this restatement impacted your conclusion regarding disclosure controls and procedures. | |
In response to your request, on December 23, 2008 we filed a Form 8-K addressing the requirements under Item 4.02. |
Sincerely, |
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/s/ Phillip A. Reinsch | ||||
Phillip A. Reinsch | ||||
Executive Vice President and Chief Financial Officer |
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cc: | Cicely LaMothe — U.S. Securities and Exchange Commission (via facsimile) Andrew F. Jacobs — Capstead Mortgage Corporation (via facsimile) David Barbour — Andrews Kurth LLP (via facsimile) Muriel C. McFarling — Andrews Kurth LLP (via facsimile) Leslie Carroll — Ernst Young (via facsimile) |