Comments on Proposed Rule:
Disclosure in Management's Discussion and Analysis about the Application of Critical Accounting Policies Securities and Exchange Commission

[Release Nos. 33-8098; 34-45907; International Series Release No. 1258; File No. S7-16-02]

• Memornadum from Jenifer Minke-Girard regarding November 5, 2002 meeting with the Accounting Committee of the American Bankers Association and Commission staff dated November 5, 2002 (File name: aba110502.htm)
• Kurt Pfotenhauer, Senior Vice President-Government Affairs, Mortgage Bankers Association of America, September 18, 2002 (File name: kpfotenhauer1.htm)
• Joseph A. Grundfest, William A. Franke Professor of Law and Business, Stanford Law School, et al., August 20, 2002 (File name: grundfest01.htm)
• Sarah G. Smith, Chief Accounting Officer, Goldman Sachs Group, Inc., New York, N.Y., August 14, 2002 (File name: sgsmith1.htm)
• Marc E. Lackritz, President, Securities Industry Association, August 8, 2002 (File name: mlackritz1.htm)
• Joseph A. Grundfest, William A. Franke Professor of Law and Business, Stanford Law School, Stanford, Calif., August 6, 2002 (File name: jagrundfest1.htm)
• Ashwinpaul C. Sondhi, Ph.D., Chair, Financial Accounting Policy Committee; Nazir S. Rahemtulla, CFA, Associate, Advocacy, AIMR, Association for Investment Management and Research, August 5, 2002 (File name: acsondhi1.htm)
• Joseph L. Sclafani, Executive Vice President & Controller, J.P. Morgan Chase & Co., New York, N.Y., August 2, 2002 (File name: jlsclafani1.htm)
• Cleary, Gottlieb, Steen & Hamilton, August 2, 2002 (File name: clearygottlieb1.htm)
• John Fosina, First Vice President, Corporate Controller, and Esther Mills, First Vice President, Accounting Policy, Merrill Lynch, New York, N.Y., July 31, 2002 (File name: jfosina1.htm)
• Henry B. Schram, Senior Vice President and Chief Accounting Officer, The Chubb Corporation, July 31, 2002 (File name: hbschram1.htm)
• Gregory W. Norwood, Bank of America Corporation, July 31, 2002 (File name: gwnorwood1.htm)
• Gerald S. Backman, Chairman of the Committee, Committee on Securities Regulation, Business Law Section, New York State Bar Association, July 30, 2002 (File name: gsbackman1.htm)
• Jeffrey P. Neubert, President and Chief Executive Officer, New York Clearing House Association L.L.C, July 29, 2002 (File name: jpneubert1.htm)
• Ernst & Young LLP, July 26, 2002 (File name: ernstyoung1.htm)
• Memorandum from Eric Schuppenhauer regarding July 10, 2002 SEC staff meeting with the Accounting Committee of the American Bankers Association, dated July 24, 2002 (File name: 071002aba.htm)
• Stanley Keller, Chair - Committee on Federal Regulation of Securities; Richard H. Rowe, Chair - Committee on Law and Accounting, Committee on Federal Regulation of Securities and the Committee on Law and Accounting, Section of Business Law of the American Bar Association, July 24, 2002 (File name: skeller1.htm)
• Karen L. Barr, General Counsel, Investment Counsel Association of America, July 24, 2002 (File name: kbarr1.htm)
• Broc Romanek, Chair of Subcommittee on Critical Accounting Policy Disclosures, American Society of Corporate Secretaries, July 24, 2002 (File name: bromanek1.htm)
• Rajeev Bhalla, Vice President and Controller, Lockheed Martin Corporation, July 22, 2002 (File name: bhalla1.htm)
• PricewaterhouseCoopers LLP, July 19, 2002 (File name: pricewaterhouse1.htm)
• Mark C. Jaksich, Vice-President & Corporate Controller, Valmont Industries, Inc., July 19, 2002 (File name: mjaksich1.htm)
• Bob Laux, Director, External Reporting, Microsoft Corporation, July 19, 2002 (File name: blaux1.htm)
• E. Follin Smith, Senior Vice President and the Chief Financial Officer of Constellation Energy Group, Inc., July 19, 2002 (File name: smith1.htm)
• Deloitte & Touche, July 19, 2002 (File name: touche1.htm)
• Billie K. Rawot, Vice President & Controller, Eaton Corporation, July 19, 2002 (File name: eaton1.htm)
• Jay P. Hartig, Chair, AICPA SEC Regulations Committee, July 19, 2002 (File name: hartig1.htm)
• Lee S. Ainslie III and Jane B. Adams, Managing Partner Senior Analyst, July 19, 2002 (File name: adams1.htm)
• Angela Seeley, Financial Reporting - CVPS, July 19, 2002 (File name: seeley1.txt)
• Andy D. Bryant, Executive Vice President, Chief Financial and Enterprise Services Officer, Intel Corporation, July 19, 2002 (File name: bryant1.txt)
• S. J. Crowe, ChevronTexaco, July 19, 2002 (File name: crowe1.htm)
• KPMG LLP, July 19, 2002 (File name: kpmg1.htm)
• Kevin Larson, Vice President and Principal Financial Officer, UniSource Energy Corporation, July 19, 2002 (File name: larson1.htm)
• Leon J. Level, Vice President and Chief Financial Officer, Computer Sciences Corporation, July 19, 2002 (File name: level1.htm)
• James A. Sears, Vice President and Chief Accounting Officer, CIGNA Corporation, July 19, 2002 (File name: jasears1.htm)
• William L. Transier, Executive Vice President and Chief Financial Officer, Ocean Energy, Inc., July 19, 2002 (File name: wltransier1.htm)
• Gerald A. Ronning, Executive Vice President and Controller, HSBC USA Inc., July 19, 2002 (File name: garonning1.htm)
• Sullivan & Cromwell, July 19, 2002 (File name: sullivancromwell.htm)
• Loretta V. Congialosi, Vice President and Controller, Pfizer Inc., July 19, 2002 (File name: lvcongialosi1.htm)
• George L. Yungmann, Vice President, Financial Standards, National Association of Real Estate Investment Trusts, July 19, 2002 (File name: glyungmann1.htm)
• R. M. Dykes, Chief Financial Officer, BellSouth Corporation, Atlanta, Ga., July 19, 2002 (File name: rmdykes.htm)
• Paul S. Graham, III, Chief Actuary, American Council of Life Insurers, July 19, 2002 (File name: psgraham1.htm)
• Alvin C. Rodack, CCM, Associate Treasurer, Ohio State University, Chairman, AFP Government Relations Committee; James R. Haddad, CCM, Vice President, Corporate Finance, Cadence Design Systems, Inc., Chairman, AFP Finacial Accounting and Investor Relations Task Force, Association for Financial Professionals, July 19, 2002 (File name: acrodack1.htm)
• Charlotte M. Bahin, Director of Regulatory Affairs, Senior Regulatory Counsel, America's Community Bankers, July 19, 2002 (File name: cmbahin1.htm)
• Gary Belitz, Controller and Chief Accounting Officer, Williams Companies, Inc., July 19, 2002 (File name: gbelitz1.htm)
• John L. Holmes, Phoenix, Ariz., July 19, 2002 (File name: jlholmes1.txt)
• Michelle Chan-Fishel, Green Investments Program, Friends of the Earth - US, Berkeley, Calif., July 19, 2002 (File name: mchanfishel1.txt)
• John D. Sheehan, Chief Accounting Officer and Controller, Delphi Corporation, July 19, 2002 (File name: jdsheehan1.htm)
• Robert M. Qualls, Vice President and Controller, IMC Global Inc., Lake Forest, Ill., July 19, 2002 (File name: rmqualls1.htm)
• Phillip Schwartz, Vice President - Financial Reporting and Associate General Counsel, American Insurance Association, July 19, 2002 (File name: pschwartz1.htm)
• James A. Bell, Vice President and Corporate Controller, The Boeing Company, July 19, 2002 (File name: jabell1.htm)
• Arnold C. Hanish, Executive Director, Finance and Chief Accounting Officer, Eli Lilly and Company, Indianapolis, Ind., July 19, 2002 (File name: achanish1.htm)
• Greg S. Tyle, General Counsel, Investment Company Institute, July 19, 2002 (File name: gstyle1.htm)
• Gordon L. Gillette, Senior Vice President - Finance, and CFO, and Shirley A. Myers, Vice President, Corporate Accounting and Tax, TECO Energy, Inc., July 18, 2002 (File name: gillette1.htm)
• William P. Hannon, Controller, Citigroup, Inc., July 18, 2002 (File name: wphannon1.htm)
• Sam L. Savge, Counsulting Professor of Management Science and Engineering, Stanford University, Stanford, Calif., July 18, 2002 (File name: savage1.htm)
• Jill Ratner, President, Rose Foundation for Communities and the Environment, July 18, 2002 (File name: jratner1.htm)
• Frank H. Brod, Chair, Committee on Corporate Reporting; David H. Sidwell, Chair, SEC Subcommittee of the Committee on Corporate Reporting, Financial Executives International, July 18, 2002 (File name: fhbrod1.htm)
• Bernd Vogt on behalf of Diamler Chrysler AG, Deutsche Bank AG, Deutsche Telekom AG, E.ON AG, Infineon AG, SAP AG, Schering AG and Siemens AG, July 17, 2002 (File name: bvogt1.htm)
• Frank Mason, CPA, Vice-Chairman, FICPA Accounting Principales and Auditing Standards Committee, Florida Institute of Certified Public Accountants, Tallahassee, Fla., July 16, 2002 (File name: fmason1.htm)
• Charles M. Nathan, Chair of Committee on Securities Regulation; Matthew J. Mallow, Chair of the Committee On Securities Regulation Drafting Subcommittee, Committee on Securities Regulation of the Association of the Bar of the City of New York, July 16, 2002 (File name: cmnathan1.htm)
• QUALCOMM Incorporated, San Diego, Calif., July 15, 2002 (File name: qualcomm1.htm)
• Bruce Feld, July 15, 2002 (File name: bfeld1.txt)
• John Y. Schreyer, Executive Vice President and Chief Financial Officer, Amerada Hess Corporation, July 15, 2002 (File name: jyschreyer1.htm)
• Memorandum from J. Minke-Girard, regarding SEC June 4, 2002 meeting with Institute of Management Accountants, dated July 12, 2002 (File name: 060402ima.htm)
• Memorandum from J. Minke-Girard, regarding SEC April 1, 2002 meeting with Financial Executive International, dated July 12, 2002 (File name: 040102fei.htm)
• W. Hardy Callcott, SVP & General Counsel, Charles Schwab & Co., Inc., July 2, 2002 (File name: whcallcott1.htm)
• Memorandum from the Division of Corporation Finance, regarding June 6, 2002 meeting with the Financial Executives International and Commission staff, dated June 24, 2002 (File name: 060602fei.htm)
• Memorandum from the Division of Corporation Finance, regarding June 7, 2002 meeting with the American Society of Corporate Secretaries and Commission staff, dated June 12, 2002 (File name: 060702ascs.htm)
• Alfred King, Spotsylvania, Va., June 12, 2002 (File name: aking1.htm)
• Memorandum from the Division of Corporation Finance, regarding February 22, 2002 meeting with the Financial Executives International and Commission staff, dated June 11, 2002 (File name: 022202fei.htm)
• James Berry, May 31, 2002 (File name: jberry1.txt)
• W. Brinkley Dickerson, Jr., May 13, 2002 (File name: wbdickerson1.txt)

http://www.sec.gov/rules/proposed/s71602.shtml