0001193125-10-124899.txt : 20100715 0001193125-10-124899.hdr.sgml : 20100715 20100520110900 ACCESSION NUMBER: 0001193125-10-124899 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100520 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MORGAN STANLEY CENTRAL INDEX KEY: 0000895421 STANDARD INDUSTRIAL CLASSIFICATION: SECURITY BROKERS, DEALERS & FLOTATION COMPANIES [6211] IRS NUMBER: 363145972 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1585 BROADWAY CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212-761-4000 MAIL ADDRESS: STREET 1: 1585 BROADWAY CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: MORGAN STANLEY DEAN WITTER & CO DATE OF NAME CHANGE: 19980326 FORMER COMPANY: FORMER CONFORMED NAME: DEAN WITTER DISCOVER & CO DATE OF NAME CHANGE: 19960315 CORRESP 1 filename1.htm Correspondence

May 20, 2010

By U.S. Mail & Facsimile to 703 813 6984

Ms. Linda van Doorn

Senior Assistant Chief Accountant

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 4561

Washington, DC 20549

 

Re: Form 10-Q for Quarter Ended March 31, 2010 filed May 7, 2010

Dear Ms. van Doorn:

Morgan Stanley (the “Company”) is pleased to respond to your letter of May 11, 2010, concerning its Quarterly Report on Form 10-Q for the quarter ended March 31, 2010.

For your convenience, we have restated your comment below.

Comment:

 

  1. We note your response to our prior comment one and your disclosure in the Form 10-Q for the quarter ended March 31, 2010. We note you describe your accounting policy for repurchase and securities lending transactions as generally being treated as collateralized financings. In future filings, please make an unqualified statement as to how you have accounted for these transactions. To the extent you have any deviations from your accounting policy, please explain and quantify these deviations in your disclosure.

Response:

In future filings, the Company will make an unqualified statement as to how it accounted for repurchase and securities lending transactions. To the extent the Company has any deviations from its accounting policy, it will explain and quantify these deviations in its disclosures.

*        *        *         *        *

In connection with responding to your comments, we acknowledge that:

 

  •  

the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

 

  •  

Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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 law of the United States.

Please feel free to contact me at 212-761-6686 if you would like further clarification or additional information.

 

Sincerely,

/s/ Paul C. Wirth

Paul C. Wirth
Finance Director and Controller

 

cc: Ruth Porat, Chief Financial Officer

Jennifer Monick, Securities and Exchange Commission

Gregory G. Weaver, Deloitte & Touche LLP

James V. Schnurr, Deloitte & Touche LLP

 

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