MEMORANDUM

To : Commission File No. S7-08-02
From : Jeffrey J. Minton
Special Counsel
Office of Rulemaking
Division of Corporation Finance
U.S. Securities and Exchange Commission
Re : Acceleration of Periodic Reporting Filing Dates and Disclosure Concerning Website Access to Reports, Release Nos. 33-8989; 34-35741

Date :

May 20, 2002

________________________________________________________________________

Division of Corporation Finance staff received a call from SNL Financial LC. Regarding the website access proposal, the caller raised a question about the "same day" filing standard. If a company electronically submits its filing to the Commission after EDGAR filing hours such that it receives a file date of the next business day, must the company post the filing to its website that night or the next day?