August 26, 2004
Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549-0609
FILED ELECTRONICALLY (rule-comments@sec.gov)
Dear Mr. Katz:
We are writing this letter in response to the proposed rule regarding the temporary postponement of the final phase-in period for acceleration of periodic report filing dates. Although CSC will be able to meet the accelerated deadlines, we encourage the Commission to extend the implementation for another twelve months. Our financial reporting system has been modified to allow us to shorten the time to gather and compile financial information. However, significant time is required for management to prepare a thorough and thoughtful analysis of the data and review it with both the Disclosure Committee and Audit Committee. The current Form 10-K and Form 10-Q accelerated deadlines are placing pressure on our financial reporting staff to compile financial data faster and allotting less review time for our management team, legal counsel, financial reporting staff, and audit committee. These pressures are even more intense during this very important period of initially complying with the provisions of Section 404 of Sarbanes-Oxley.
The Commission issued the Accelerated Report Filing Dates prior to Section 404 being enacted. We think if the effort of complying with Section 404 had been considered, a more gradual ramp to the 60 day Form 10-K and 35 day Form 10-Q would have been selected. Many of the same personnel documenting, analyzing and testing the internal controls required by Section 404 are critical to the preparation of financial statements. For these reasons, we support the temporary postponement of the final phase-in period for acceleration of periodic report filing dates by at least twelve months. This would give ample time to complete the Section 404 requirement and further improve the quality of our disclosures.
Sincerely,
Donald G. DeBuck
Vice President and Controller