September 30, 2004
Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549-0609
RE: File Number S7-32-04
Dear Mr. Katz:
This letter is in response to the proposed rule regarding the temporary postponement of the final phase-in period for acceleration of periodic report filing dates. We support the postponement of the accelerated deadlines for both the 10-K and the 10-Q. The current 10-K and 10-Q deadlines of 75 days and 40 days for accelerated filers are placing pressure on our financial reporting staff to compile the data and allow time for review by management, legal counsel, the external auditors and the audit committee. These pressures have increased as we are preparing to comply with the provisions of Section 404 of the Sarbanes-Oxley Act. Many of the personnel involved with Section 404 compliance are the same ones critical to the financial reporting process.
For these reasons we support the postponement of the accelerated deadlines for at least twelve months and believe the commission should consider leaving the deadlines as they currently exist to help assure quality reporting.
Sincerely,
Sherri Billings
Executive Vice President/Chief Financial Officer