Responses to ACSPC Request for Public Input

Accounting/Auditing

Question 19. Is the quarterly Form 10-Q or Form 10-QSB information valuable to users of the financial statements of smaller companies? Would a system that required semi-annual reporting with limited revenue information provided in the other quarters reduce costs of compliance without decreasing the usefulness of the reported information to investors? Please explain.

The following answers have been received:

08/02/2005 13:57:44   Actually, most investors do expect to receive or be able to look at a 10-Q, even for a smaller company. Small companies are used to providing Qs, and that is not the problem at all.

08/02/2005 17:44:12   Financial reporting on a quarterly basis is good. The amount of disclosure should be reduce just to focus on the financials and some limited MD&A and have the rest of reporting requirements happen annually.

08/02/2005 23:36:32   Companies should continue to report quarterly.

08/03/2005 01:39:17   No. Quarterly reporting is fine. The reviews by auditors have added too much expense. If tort reform were first pursued, all the rest of this could settle into something logical. The real problem is that audit firms are forcing these reviews and audits to dramatically exceed the appropriate volume of work, in their fear regarding litigation. Auditors were never properly intended to make guarantees to investors. This is very misplaced responsibility, implied only to serve the interests of plaintiff's attorneys.

08/03/2005 07:01:34   go semiannual...with appropriate 8k interim disclosure...

08/03/2005 08:55:04   These are positive filings and are not that expensive to file.

08/03/2005 08:58:39   We are not traded and I doubt that anyone outside our board reads a 10Q or even knows what it is. This again is a small town community bank owned by the locals in the town.

08/03/2005 10:40:26   We already provide quarterly Call Reports which contains 99% of the information found in a 10-Q, and this information is public. Perhaps there should be some consideration of the type of small business. The banking industry is already highly regulated. Obviously, reducing the requirements to semi-annual would reduce costs.

08/03/2005 12:17:58   yes. less is better

08/03/2005 13:55:42   Quarterly statements are just good business. Smaller companies might benfit by doing quarterly, then Sox yearly.

08/03/2005 15:01:40   The present system is OK.

08/03/2005 15:22:49   As a bank filing quarterly call reports, this requirement does not cause a burden. Perhaps we should rethink the historic requirement of quarterly reporting to semi-annual reporting for both regulatory and accounting requirements.

08/03/2005 16:58:51   I really don't know how to answer this. I doubt our 10Q's are being reviewed in much detail by our investors and they do cost us a lot to produce. However, they have the right to see the numbers if they want. 10Q's don't bother us too much since we've been doing them already and we have a good process of completing them in place already. If this cost were reduced without effecting shareholders, we would be OK with it.

08/03/2005 18:01:35   Please look into item no 29

08/03/2005 18:05:44   A system of semi-annual reporting with limited revenue information for the other quarters would reduce the costs of compliance without decreasing the usefulness of the information to investors.

08/03/2005 18:30:29   x

08/03/2005 19:54:33   In my opinion, the 10Q and 10QSB is difficult to understand for the average stockholder. It requires a translator to make the forms understandable. A simpler system can be devised to facilitate the reporting of a company's financial health. The limiting of revenue information is not desireable either. But when opinions are made by the auditor, they should be made within the scope of the auditor's level of expertise.

08/03/2005 19:55:50   THE MORE INCREMENTAL INFORMATION THAT IS MADE AVAILABLE BY SMALLER PUBLIC COMPANIES, THE BETTER A POTENTIAL INVESTOR CAN PERFORM DUE DILIGENCE! SEE ITEM #5 ABOVE!

08/04/2005 09:39:15   This is valuable. Once again, the better question is does this make sense for large companies. Small companies change very, very fast and six months is an eternity for a company that is small just trying to survive.

08/04/2005 10:40:16   Our forms are filed with the FDIC and to my knowledge, are not publicly available. Our shareholders have access to our quarterly call reports but not to our quarterly Qs. It makes no sense to me that we file reports that no one but us and our regulators see.

08/04/2005 12:09:05   I think it is important to report quarterly. However, I think the 1st and 3rd quarter disclosures could be reduced. A full blown MD&A for a small company from quarter to quarter is rehasing the same thing over and over. It's like crying "wolf"...when we say the same things, people end us not reading it. If we did a 6/30 MD&A (midyear) and then the 10K MD&A and disclosures at year end, I think it would be much more meaningful and effective to the shareholders. PLus, as a public company, we all release quarterly results to the public.

08/04/2005 13:38:24   N/A

08/04/2005 13:53:47   Probably.

08/04/2005 14:20:27   To a lesser extend yes, but I would prefer you spent your time on revising SOX>

08/04/2005 18:05:44   Yes

08/05/2005 10:54:31   Yes, keep it quarterly

08/05/2005 12:38:34   See item #5 above and then ask yourself if the current frequency of filing is adequate? If it is adequate then is the oversight lacking?

08/05/2005 12:44:28   I don't anyone that reads SEC quarterly information. The formats are horrible and most of the information is useless.

08/05/2005 15:34:53   Less information would be less work, less work would be less cost. Our stock is not traded heavily so I do not believe that going to semi-annual Q's would impact our investors.

08/05/2005 15:43:46   Small banks are required to produce quarterly Call Reports for Federal bank regulators. That repporting system has been refined of more than 5 decades. Could the SEC consider the use of that report or some scaled down version thereof and elimiate another report and the cost of preparation?

08/05/2005 16:45:38   The 10-Q is absolutely useful. You can always read the 10-Q to see where they are bullsh*tting the investors on the conference calls (calling a poor quarter a very successful validation of their business model while losing millions is total bunk and comes to mind).

08/05/2005 19:33:08   It might be helpfull for new public companies, but for companies already setup to do 10-QSB's I don't think it would do much except reduce our auditing fees.

08/06/2005 13:52:06   Quarterly reporting should be maintained. Consideration should be given to reducing sdome of the requirements to reduce cost and time required to comply.

08/08/2005 09:29:48   Keep it the same. When investors look at reports, conformity is the first tool to comparability.

08/08/2005 11:10:11   no, I believe the quarter reporting as it is does not cause an undo burden.

08/08/2005 11:39:29   I receive little request for 10Q's and would love to know how many people actually read them. Today, many 10Q's resemble annual reports without the oppinion. One 10Q and one 10K or even two documents that more closely resembled a 10K would be sufficient.

08/08/2005 14:06:10   I think quarterly is fine as is. I think semi-annually is too long to go between providing financial information to investors.

08/08/2005 15:43:24   Absolutely. Quarterly reporting should be continued for all public companies. The whole issue is timely reporting of information that effects investors. As an investor I would strongly oppose any reporting less frequently than quarterly. However, 8-K reporting of Reg FD quarterly financial information may be sufficient as opposed to full form 10-Q's in smaller companies.

08/08/2005 21:39:10   Much of the information contained in the 10Q/10QSB is redundant and is simply a repetition from past filings. Most investors look at the financial statements of the Q's as well as any other pertinent information that has changed from past filings in order to assess their investments. Changing to semi-annual reporting will not save reporting companies very much over the current system. It would seem relevant if the quarterly financial statments were filed, but other information that is a repetition from the 10K being eliminated so investors could rely on the 10K and subsequent Q financials and 8k's in order to assess the companies.

08/09/2005 09:30:31   No. Few shareholders refer to Form 10-Q.

08/09/2005 16:26:34   I do not see that the 10-Q's should be abandoned for smaller companies. However, we need to avoid the information creep that we are seeing as the 10-Q's continue to grow.

08/09/2005 17:25:10   Yes. I would leave current 10Q process alone.

08/10/2005 09:04:41   no commdent

08/10/2005 13:44:39   I honestly don't think any of our investors look at our 10Q. We have 658 primarily local shareholders who just like having a piece of the local bank. The annual financial statements and mind boggling to the vast majority of our shareholders. Semiannual reporting would certainly save some time, and certainly would not decrease our shareholders knowledge of our financial situation.

08/10/2005 16:00:18   We have always provided quarterly reports to our shareholders and anyone else who wanted one. Form 10Q says the same thing we were always saying but with more meaningless, repetitive verbiage.

08/10/2005 17:18:15   Quarterly reporting is the correct format.

08/10/2005 22:09:27   This is not a big problem. Small companies want this information anyway or at least I think they should

08/11/2005 08:35:22   Nope. Annual reporting should suffice.

08/12/2005 13:12:10   Those reports do have value, no question. Less frequent,less comprehensive reports would help reduce costs, no question. This is particularly applicable to banks because of the frequency and availability of FDIC Call Reports.

08/12/2005 16:35:01   Yes, I believe this would reduce costs without compromising the quality or usefullness of information.

08/13/2005 12:39:43   It might, but it would have little effect on the company.

08/15/2005 13:08:27   Quarterly reporting should be maintained. Any company with proper accounting controls is preparing financial statements on a monthly basis. Quarterly reporting in its most basis form is just not that burdensome.

08/15/2005 14:27:30   Commissioner Wheat accurately predicted years ago that quarterly reporting would be a disaster for financial markets. He was right but the problem applies equally to large and small companies. I think investor expectations are such that a company that chose not to report quarterly when others did so would suffer in the market.

08/15/2005 15:10:05   Semi annual could be interesting especially if they agree to also reporting on internal control changes to the initial year's results.

08/15/2005 15:13:01   I don't believe the information is useful on a quarterly basis. Similar to my above response, the investors need to weigh in here. Institutional investors in particular. I don't care so much about what "Aunt Martha" says, I care about what the institutions want. Aunt Martha can go invest in IBM, Microsoft, GM if the institutional shareholders don't value the information.

08/15/2005 15:14:45   Q's have the ability to provide a lot of valuable data. The numerics only provide one side of the review, the real emphasis should be on the quality of the MD&A. SEC does a very poor job in this regard.

08/15/2005 16:33:43   I think quarterlies are valuable, and I would not do away with them- twice a year is too few.

08/15/2005 16:41:14   yes

08/15/2005 18:59:52   I think people are used to quarterly updates and semi-annual reporting would be a step backwards. For many companies (e.g. R&D, biotech companies), revenue is not the key factor but financial disclsoure is still important.

08/16/2005 09:51:21   Yes. I would not change quarterly filing requirements for smaller companies. If a company can not get out quarterly reports, than they should not be public.

08/16/2005 10:10:36   Yes, it is important. The issue is the accelerated filing dates. The faster filing results in more costs and increases the risk of error.

08/16/2005 10:21:17   Yes. No.

08/16/2005 10:26:28   yes, quarterly burden too high. if disclosure hurdles set so that disclosures are made timeously, half yearly burden is sufficient

08/16/2005 10:42:02   Quarterly number should continue to be required.

08/16/2005 10:44:16   I hope it is valuable. We spend lots of time preparing and completing these reports. I feel like our investors value the info.

08/16/2005 11:18:54   I am okay with the current system.

08/16/2005 11:52:16   Who ever wrote this paragraph deserves a gold star. I just commented to our CEO that we may as well just write and file 4 10K's a year. It would be easier than what we are currently doing. We would strongly support reduced disclosure on the quarterlies.

08/16/2005 12:15:34   I think that the information provided is valuable, but I'm not sure how many people actually look at it. We have lots of communications to the public with quarterly earnings releases, conference calls that are web-cast, 8-K filings, press releases, etc. that you end up stating the same information multiple times which can be overkill.

08/16/2005 12:40:54   Possibly. What would thr trial bar do?

08/16/2005 13:04:14   Preparing quarterly financials is not a hardship and must be done as a minimum in order to provide your board of directors with financial information. It's the cost of legal and accounting fees that is questionable. It would lower the cost of compliance if only semi-annual reports were needed to be reviewed by the auditor and legal counsel.

08/16/2005 13:12:04   The implied semi-quarterly approach would be helpful; the present "Q" is too detailed and contains too much accounting minutia for the average investor to understand.

08/16/2005 13:19:29   As an FDIC bank, we already have quarterly reports that provide our shareholders with adeqaute information. In my opinion, smaller financial institutions should be allowed to forego 10-Q or 10-QSB filing provided they are filing quarterly call reports.

08/16/2005 13:20:23   Its as valuable to users of small companies as large companies. While I personally feel that quarterly reporting encourages negative corporate behaviour with too much focus on short -term results, I think it would be worse to have different reporting periods based on company size. We need to simplify and clarify GAAP and reporting, not continue to differentiate or make "exemptions" and make today's mess worse.

08/16/2005 13:25:32   The quarterly reporting of the SEC is not an onerous burden. If a company, no matter the size, is going to have its securities trading in open markets, some form of current reporting is a must. However, the cost of auditors involvement has more than doubled as another unintended consequence of SOX.

08/16/2005 13:27:00   Yes.

08/16/2005 13:30:33   Quarterly is fine.

08/16/2005 14:08:05   Limited information being reported quarterly would still need to be reviewed, thus not reducing costs very much.

08/16/2005 14:23:10   I believe that the Form 10Q system should remain the same. Too many economic events can change over a semi-annual reporting period and invstors may be at a disadvantage.

08/16/2005 15:15:12   For most small companies the information provided on the quarterly forms is seldom used. Therefore moving the required reporting to semi annually would have little impact on investors. Only reporting semi-annually would obviously make it easier for the company, but if the information is seldom used, why report at all?

08/16/2005 16:08:50   I think quarterly information is fine for smaller companies.

08/16/2005 16:09:47   No opinion.

08/16/2005 16:16:04   Yes it is useful and ever increasing. However, some disclosure relief would be welcome and would not impair the material relevant information a shareholder requires.

08/16/2005 16:45:09   Today we basically have the SB level of reporting and a higher level for all others (below or above $25 million in sales.) We think the SB level is to low and having everyone above that level puts very small simple companies in the same category as very large and sophisticted companies. The top band is too large. We think that a change in reporting for small companies is necessary and should include various criteria including trading levels, volatility of earnings, actual performance relative to expectations and significance of changes in performance. The investors should help to determine what is appropriate. Companies should also have a say. A company that decides to "under" disclose will loose investor interest.

08/16/2005 18:35:41   I believe our 10-Q constitutes important information. Why it's necessary to include quarterly disclosures of effective income tax rate reconciliation to statutury rate, pension plan actuarial data, and estimated contractual obligations is a mystery to me.

08/16/2005 21:29:07   Uncertain.

08/17/2005 12:28:22   Could reduce the cost of preparation, but we use it to communicate to investors, so if the 10-Q is eliminated, we would offer a simpleifed report.

08/17/2005 12:36:00   I think the quarterly system is fine. Any variation on the balance sheet/income statement presentation would likely cause more confusion for both investors and preparers. I'm in an industry in which the cash flow statement is of little use, but understand its vitality for other industries.

08/17/2005 12:48:33   YES. Investors are not that sophisticated and only want basic info.More sophisticated investors will call the Company.

08/17/2005 13:25:50   I would say that fewer than 10 MVB Financial Corp shareholders look at the 10-QSB or 10-KSB. The 10-KSB accounting disclosure is meaningless to 99% of our shareholders.

08/17/2005 18:49:27   The 10Q information is definitely valuable to investors. In my experience most investors (even major fund managers) and equity research analysts are not accountants and certainly not auditors. As such I believe very few really understand all our accounts (try understanding the accounting for our tax provision or our UK defined benefit pension plans). In my opinion, financial reporting should (in fact I think it needs to or otherwise it risks becoming increasingly irrelevant to investors) be more focused on how the company generates operating profit and cash flow and less on non-cash charges like stock comp expense, a lot of purchase accounting, and goodwill and intangible accounting. GAAP rules have increasingly blurred two concepts: profit (i.e., revenue less expenses of creating that revenue) and changes in the present value of future assets or liabilities (most of the non-cash charges like impairment of assets or the creation of contingent future liabiliteis like stock based compensation). I believe most investors still really want to know what the operating profit of the company was, how it compares to last year and how it compares to other companies. GAAP, with its confusion of operating profit with changes in the present value of future assets and liabilities obfuscates this, not clarifies it. Did you know it is quite possible to create a GAAP income statement without ever usign the word profit?. This is NOT in teh interest of investors. This is why so many companies use non-GAAP information. The problem with this is the non-GAAP information is not comparable across companies and therefore fails one of the key reasons for having accounting standards in the first place. The FASB could resolve 90% of this problem in a single stroke by providing a GAAP definition of EBITDA. Why they do not do so is a TOTAL mystery to me - it is the information every investor wants, but every company does it differently and nobody ever audits it!!

08/17/2005 19:31:08   I think quarterly disclosures are appropriate. 6 months is too long and too much could happen. I don't mind being accountable to my shareholders on a quarterly basis.

08/17/2005 21:27:12   Yes. In my opinion 10Q's and 10K's of smaller companies are not being utilized by investors. They are much too complex and a significant portion of the reports consist of legal discliamers. Almost half our our 10Q is taken up by our risk facotrs section. This has no value to investors. Reducing complexity or filing frequency is a great idea.

08/17/2005 22:55:14   The quarterly Form 10-Q information is of primary benefit in comparing revenue and cash flow trends,as well as MD&A discussion, in many cases. Semi-annual reporting with limited revenue reporting would potentially decrease the compliance costs somewhat, but not to any significant extent. I am not in favor of changing this at this time.

08/18/2005 08:03:31   Not Applicable

08/19/2005 02:56:12   Quarterly is good. It isn't a signficiant burden, but the level of quaterly reporting seems to be rising to nearly the level of annual reporting - that's a bit of a challenge.

08/19/2005 11:44:44   I'm not sure how many people actually read our 10-QSBs. I'm skeptical whether going to a semi-annual format would actually be less burdensome however - you have to keep track of two separate types of reporting formats.

08/19/2005 12:28:03   Definately a cost reduction would enhance the ability of the entity to provide increased shareholder returns.

08/19/2005 13:49:01   Since an informed investor is the best investor, it is not felt that the Form 10Q should be diluted in any way. There should be no reduction to the quality of information that is given to investors by limiting the quarterly presentation of revenue data; the current format for presentation is adequate, but not excessive, from an investor´s perspective.

08/19/2005 14:40:28   As an investor, less frequent reporting from a smaller public company would not be preferrable.

08/19/2005 14:50:07   Our subsidiary thrift provides a detailed financial report quarterly to the Office of Thrift Supervision. This report is available for public scrutiny on the FDIC website. So for holding companies such as First Bancorp whose primarily activity is to hold the stock of a bank or thrift, semiannual SEC reporting would probably be sufficient.

08/19/2005 17:03:28   considering this type of thing should be secondary to lessening the burden of 404 for smaller companies.

08/21/2005 03:34:34   I think the quarterly information is usefull to investors.

08/21/2005 22:19:50   Yes.

08/22/2005 14:21:23   Less frequent reporting would reduce costs but should be avoided. A lot can happen in 3 months let alone 6! Instead the notes MUST be reduced. The requirements are too burdonsome and result in a "book" which I bet few read!

08/22/2005 15:20:23   Small companies should continue to report quarterly, as I believe their investors are just as interested in results as larger company investors. Reporting could be reduced to just an income statement and balance sheet, but I believe that MD&A and notes are a critical tool in helping investors understand the financial statements. I would stick with the requirements we have now.

08/22/2005 15:47:02   I would definitely favor semiannual reporting.

08/22/2005 15:47:34   The impact of not reporting quarterly would not be to our cost of compliance it would be to our share price. Our share price responds at each quarterly report. Actually, we look for opportunities to communicate with our investors, not the other way around.

08/22/2005 17:54:28   The entire business world runs on a quarterly system. There is no value in changing this. 10-Q's are not that onerous.

08/22/2005 17:56:59   I think the current system is fine.

08/22/2005 19:27:18   I honestly don't think 10-Qs take that long if you know whatyour business is doing.

08/22/2005 20:10:17   I believe investors are used to seeing quartely results and that should not be changed. It's not a problem filing quarterly, it's a problem having so many CPA's in the loop. Perhaps the quarterly reports should not require the auditor and a concurring reviewer.

08/23/2005 00:42:38   no benefit. investors are entitled to know each quarter how a company is doing.

08/23/2005 15:56:30   Information in 10Q's beyond the financial results is often redundant and uniformative. Semiannual would help. 8k disclosures are adequate to keep investors informed of major items.

08/23/2005 16:06:08   Quarterly reporting seems about right. Not too much, not too little.

08/23/2005 16:49:34   This could be quite a cost saver and probably would be all that is needed.

08/23/2005 18:10:00   Would be preferred, yes.

08/23/2005 21:11:03   yes, reducing the complexity of 10Q filings would be a benefit as long as material disclosures,i.e. 8K's are maintained.

08/24/2005 10:14:02   current 10QSB reporting requirements are acceptable and appropriate

08/24/2005 12:24:07   no, 10Q process is fine.

08/24/2005 14:30:13   I think if you go away from quarterly reporting as it is, you lose focus in a lot of ways. The current process requires a company to prepare and review its business quarterly and going to semiannual would lose that process and focus.

08/24/2005 16:19:27   That works or keep the current system but only require an auditor review seminannually. Let us consult on accounting issues with our auditor involvement before 404.

08/24/2005 16:26:56   We do not believe such a system would provide a significant advantage over the current system.

08/24/2005 16:54:47   Q's are adequate

08/24/2005 20:16:09   Shareholders like quarterly reports. We need to have the definition of an accelerated filer changed from 75MM to give the small company more time to file.

08/25/2005 15:23:41   N/A

08/25/2005 16:26:29   There would probably not be a significant imapct on costs to report annually versus semi-annually.

08/25/2005 17:02:43   Yes. Quarterly reporting is fine. Semi-annual reporting would make seasonality considerations much harder for the investor to measure.

08/26/2005 12:41:42   I notice that public companies in Europe report on a semi-annual basis. This is an interesting idea that has some merit.

08/26/2005 13:07:22   The 10-Q reports have not added a great deal of burden to our company since we have other quarterly reports requiring similar information which must be furnished our bank regulatory agencies.

08/26/2005 15:31:29   N/A

08/26/2005 16:22:08   Yes. I don't believe the 10-Q system should change for smaller companies.

08/26/2005 17:46:13   Moving to a semi-annyal reporting will certainly help.

08/27/2005 11:21:03   Yes, but on a limited basis. The quarterly report information mostly tells investors how soon the company cash will run out. No other information provided is useful, if the Registrant uses Form 8-K properly.

08/28/2005 23:37:43   10-K reporting would likely suffice for firms with market cap under $500MM.

08/29/2005 07:07:37   Absolutely. For a small company there is more short term volatility - sometimes misleading.

08/29/2005 10:21:15   We would hope that it is valuable, although where there are limited shareholders and smaller market capitalization it is tougher to prove that the end product actually gets reviewed that regularly. Nothing in the amount of stock trading would indicate that it makes a significant difference, as long as nothing drastic is reported.

08/29/2005 10:21:25   We would hope that it is valuable, although where there are limited shareholders and smaller market capitalization it is tougher to prove that the end product actually gets reviewed that regularly. Nothing in the amount of stock trading would indicate that it makes a significant difference, as long as nothing drastic is reported.

08/29/2005 11:21:29   The 10-Q and QSB provides valuable information and should remain intact.

08/29/2005 14:18:47   The quarterly information is valuable to users of financial statements of smaller companies; any system that reduces the frequency and content of the information to the users will also diminish its value to the users. You simply cannot subtract information from the information package and still have the same information content for users.

08/29/2005 14:53:30   Yes. Would a system that required semi-annual reporting with limited revenue information provided in the other quarters reduce costs of compliance without decreasing the usefulness of the reported information to investors? No. Please explain. Information worth having needs to be timely.

08/29/2005 15:31:21   Going to a semi-annual reporting requirement would save costs (SAS 100 reviews), without negatively impacting the usefulness of the information, especially if limited earnings information was made available quarterly. A company could still provide quarterly financial information to shareholders. In addition, banks have a quarterly financial reporting requirement already with the Reports of Income and Condition (Call Report).

08/29/2005 16:10:53   Very costly to prepare, but yes---- probably useful to some investors. Not sure of the appropriateness of the second question---but it might be helpful and less costly.

08/29/2005 16:20:53   Again in my opinion for a financial institution, our quarterly Uniform Bank Performance Reports actually provides more information with peer group data and ratios for investors to review.

08/29/2005 17:09:27   Quarterly 10-Q's are useful. Shortening the time frame would be difficult for smaller companies.

08/29/2005 17:12:26   I think the current information and timing is OK.

08/29/2005 17:36:32   We have never had a question from a prospective invetor regarding information from our filings. I don't think most people even look at them. If reducing the reporting has the impact of reducing cost and time spent by management of small companies it would indeed be a blessing.

08/29/2005 19:02:32   Semiannual would probably be adequate.

08/29/2005 19:05:24   The purpose of interim reporting should be to “refresh” the information previously provided. However, the quarterly reporting requirements have evolved to a point where the effort involved in issuing the financial statements and related notes for a 10-Q is nearly as extensive as the effort related to issuing the financial statements and related notes for a 10-K. As a result, the resources devoted to quarterly filings are significant. Furthermore, because quarters are such a short period of time, we believe that quarterly reporting results in undue emphasis on short-term fluctuations rather than longer term trends. Therefore, we support semi-annual reporting with limited revenue information provided in other quarters.

08/29/2005 21:00:01   I think less frequent reporting by smaller companies would definitely reduce the costs of compliance. As long as there were no significant events, the usefulness to investors would not decrease. Significant events would need to be disclosed perhaps in more detail within an 8-k.

08/29/2005 22:40:58   It would certainly reduce costs, but I think the system of quarterly reporting is still necessary for investors to have timely information to base their decisions.

08/30/2005 15:04:16   Quarterly reporting is appropriate and necessary for investors. However, the information disclosure requirements are too restrictive in two ways: a. Too much information is required and/or redundant b. Information disclosure is too restrictive preventing subjective explanation to investors.

08/30/2005 15:07:00   The Form 10-Q could be reduced for some of the disclosure, for example, option remaining contractual life, and it would not impact investors or the usefulness of the information. The required disclosure should be evaluated and only include what truly is helpful.

08/30/2005 16:27:18   Yes, semi annual and simpler reporting would ease the burden without materially affecting the accuracy of the financials.

08/30/2005 17:08:46   Yes, we believe that the current quarterly reporting requirements are valuable to users of the financial statements. It is possible that a system that required semiannual reporting with limited revenue information provided quarterly in other quarters would reduce compliance costs without decreaseing the usefulness of the reported information to investors.

08/30/2005 17:23:36   I think the Qs are useful and don't think that semi-annual reporting would be fair to our investors.

08/30/2005 18:26:14   Our company is classified as a “voluntary filer” because our indenture requires us to comply with the reporting requirements of the Securities Exchange Act of 1934, and our securities are only offered to qualified institutional buyers. Quarterly Form 10-Q information is only marginally valuable to the users of our financial statements, who tend to be long-term investors not swayed on a day-to-day basis by company news and information. Providing them with semi-annual reporting with limited revenue information provided in the interim quarters would definitely reduce costs of compliance without decreasing the usefulness of the reported information to investors.

08/30/2005 18:48:02   A 10Q is definitely overkill when it comes to details! Investors would prefer, and get a lot more out of, the semi-annual reporting system with limited info. provided in the other quarters.

08/30/2005 18:51:48   We believe that the quarterly information is valuable to users of the financial statements of smaller companies. We would not suggest semi-annual reporting.

08/30/2005 21:07:56   Yes, revenue data for smaller companies is the primary focus of users of financials.

08/30/2005 23:57:28   Yes, it is valuable. Not suggest for semi-annual reporting. Quarterly report can provide updated information to investors.

08/31/2005 10:19:14   I believe a semi-annual presentation for smaller companies with data of the first and second fiscal quarter would be adequate and reduce the burden for such companies in producing 3 Form 10Q reports.

08/31/2005 10:21:37   Investors want no more than revenue and earnings with an explanation for change.

08/31/2005 14:00:12   Yes. Quarterly reporting is appropriate, except perhaps for very small companies.

08/31/2005 14:00:16   Quarterly filings are useful to all parties - investors, etc. For our company, reducing filings would be drecrease costs of compliance very much. The auditors' quarterly review fees would reduce in # but semi-annual reviews would take longer and therefore would cost more than a quarterly review.

08/31/2005 14:12:37   The notion of a system that required semi-annual reporting with limited information provided during other quarters is one that deserves additional consideration. Most investors in smaller companies are primarily concerned with revenue, income (loss) from operations and sources/uses of cash. Providing only this information each quarter and full reporting on a semi-annual basis would most certainly reduce the costs of compliance while still providing investors with the most important information they need for their decisions. However, similar to a previous response, any such proposal would have to be to ensure that the absences of quarterly reporting for smaller companies does not signal that the control environment at a smaller company is not as robust as a larger company. This perception would likely result in an investor´s willingness to pay a premium for equity in a larger company (reporting full results on a quarterly basis) vs. a smaller company (with only semi-annual detailed reporting).

08/31/2005 14:25:37   For the average investor the 10Q - 10QSB is now filled with useless garbage when looking at a small company. A small business report that shows usefull financial information is all that is needed. I only ask a loan customer for annual profit and loss balance sheet and tax returns. I own stock in about 30 companies, most are small. I look at about 8 to 10 itmes in the annual report. I don't look at who certified. If the audit company gives an opinion that I can read, that is fine.

08/31/2005 14:32:46   The 10Q or 10QSB does contain information valuable to investors of smaller companies. Since management is very limited in what they can communicate to the public, these forms are truly the best source of information to base an investment decision on. While going to a semi-annual report may save somewhat on compliance costs, I doubt it would be a significant savings if you are still required to report limited information in the other quarters. Maybe a better solution is to loosen the restraints of what can be communicated, outside of the quarterly reports, to current and potential investors.

08/31/2005 15:19:27   Yes/No. Creating a new system would initially create more costs (legal, acctg, etc) and little investor confidence (not familiar with reports). It sounds like a good idea, but is increasing the diverstity in reporting and providing the investors with another form that they have to understand.

08/31/2005 16:05:33   Yes mostly definitely it would reduce the costs. Most of our members don't read our reports. They are mainly used by our competitors to see what we are doing which gives us an unfair disadvantage.

08/31/2005 16:13:45   Semi-annual reporting would be an improvement. Reporting of statement of condition, statement of income and statement of cash flows provides the most useful information to investors.

08/31/2005 16:16:33   19. Investors generally prefer more information about their investments as opposed to less information. Due to the inherent risk of small companies, it is important for investors to be constantly informed on the progress of the companies. Larger companies generally have a larger review base, including stock analysts and independent reviews that are not as widely available for small companies. Our company believes that the 10-Q reporting process is currently not a burden to smaller companies.

08/31/2005 16:29:59   The 10-Q is way out of hand. I do not beleive 1/4 of 1% shareholders or potential investors get past the income statement. Yes, your semi-annual sugestion would be perfect, other quarters, condensed income statement and balance sheet with no more than 1/2 page explaination.

08/31/2005 17:16:33   Quarterly reporting is not a burden

08/31/2005 18:22:30   The quarterly information is valuable to users of the financial statements of smaller companies. The issue is, there just aren't that many users of those financial statements. We suggest that quarterly financial statement and disclosure requirements be scaled back to be less costly. Some specifics are: • MDA requirements could apply at year-end and at the 6 month point, but not at the first quarter nor the third quarter. • 10-QSB requirements could apply only at the 6 month point, but not at the first quarter nor the third quarter (thus, this would need to be retitled as something other than a 10-Quarter, such as a 10-Semiannual). The limited public interest in smaller companies indicates that less information is required. Said another way, if a large company has 10 million shareholders and a small company has 500 shareholders, shouldn't the large company provide more information and do it more frequently than the smaller company--but today they both provide about the same information on the same frequency.

08/31/2005 18:23:08   It may reduce the cost, but a minimum amount would always need to be done. Focus on financial statements plus on the management discussion and analysis, and overall business discussion vs. meeting technical standards.

08/31/2005 19:16:05   19. Investors deserve to receive financial information from their companies no matter what their size. The SEC needs to understand that simpler organizations will require simpler disclosure than a conglomerate.

08/31/2005 20:55:07   We have gotten used to preparing forms 10K, 10Q. This is costly to us as we need the auditors buy off as well as our corporate attorneys. Unless there were to be a major change, I do not see any value in tempering it.

09/01/2005 00:55:31   N/A

09/01/2005 11:40:19   No, I believe quarterly reporting is important and not too cost prohibitive.

09/01/2005 14:30:54   Quarterly reporting obviously makes financial information available more frequently. But, unusual events, positive or negative, must be released in any case. Semiannual reporting would reduce costs, but exemption from SOX Rule 404 would be a far more effective way of reducing costs.

09/01/2005 17:12:34   I think the information is useful. Most of the information is needed by management to effectively manage the company.

09/04/2005 07:42:16   No. Quartely filings are important to support investors

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