From: John Ritchie [John.Ritchie@efi.com]
Sent: Wednesday, May 08, 2002 5:37 PM
To: 'rule-comments@sec.gov'
Subject: File No. S7-08-02




> rule-comments@sec.gov
> 
> Comments  to File No. S7-08-02
> 
> Dear Sirs:
> 
> As a Vice Preside of Finance , I find your proposed acceleration of filing
> to be in opposition to providing investors with complete and accurate
> filings. While most audits and reviews are completed before the filing
> deadlines you propose, the process of preparing the SEC documents are not.
> The financial statements are only a part of what needs to be prepared.  To
> properly analyze, prepare and review the MD&A section takes additional
> time.  The SEC has recently stressed the need to not use boilerplate in
> this section however, the new time deadlines would will not help in
> resolving the "boilerplate" issue  .  Preparation in the time-frame being
> proposed would mean that parts of this section would be written before the
> reporting period was ended.  Early preparation does not allow for a
> complete evaluation of the information used to prepare this section. Once
> completed, the document must be reviewed, not only within the organization
> preparing the documents, but by the chosen auditing firm and by legal
> counsel.  Rushing through this process will not enhance the information
> given to the investors.  The adage "Haste makes waste" comes to mind.  
> 
> I have one quick comment in response to your second proposal requiring
> companies subject to the accelerated filing deadlines to have their
> reports on-line on their Internet web-site the same day as they file.  If
> the SEC cannot have the day's filings available immediately, why do you
> expect that the filer would be able to have it available immediately?
> Many companies use outside services to maintain their web-sites.  If they
> furnish a copy of their filing to those services at the same time that
> they file, there may be a 24-hour delay before it can be placed on the
> web-site.  In some cases, it may be longer.  And while we like to think
> that all SEC regulated companies would have a web-site, there may be some
> that do not.  Will you require them to establish a web-site to publish a
> document that can be obtained from the SEC EDGAR archives?
> 
> I find your proposed ruling a quick response to a very bad situation, with
> little thought given to whether the ruling will truly add anything of
> value for investors.
> 
> John Ritchie
> Vice President of Finance 
> Electronics for Imaging, Inc.
>