TO:	Files
FROM:	J. Minke-Girard
RE:	Release Nos. 33-8089; 34-45741, File No. S7-08-02
DATE:	July 12, 2002

On June 4, 2002, Chief Accountant Robert Herdman and Professional Accounting Fellow David Kane met with representatives of the Financial Reporting Committee of the Institute of Management Accountants. Following are comments received from that group.

Accelerated Reporting

• The IMA was generally not supportive of the proposal because its membership is primarily comprised of small companies, who feel that if the reporting deadlines are accelerated, the quality of financial data would diminish. Some members also stated that the associated costs of the proposal would exceed the likely benefits.

• In general, the IMA's concerns were largely around the accelerated filing deadlines for quarterly reporting.

• IMA was generally supportive of the Commission's web-based initiatives.