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Archive for the 'comment letters' Tag

Comment letters: too late to be much use at Shufflemaster…

Wednesday, July 9th, 2008

Back in May 2005, the SEC began releasing comment letters on its site. But three years later, the system still doesn’t quite work because the only time they become available on the SEC site is after whatever issue the SEC is concerned about has already been resolved. I thought about this while reading the revised [...]

The SEC takes another roll of the dice at Las Vegas Sands…

Tuesday, May 13th, 2008

Comment letters can often be difficult to get a handle on. Some people, like my friends at Disclosure Insight, (formerly SEC Insight) put a lot of credence in them. Others, say they’re interesting, but not particularly informative. I was thinking about this because late Friday, Las Vegas Sands (LVS) filed this 10Q which noted that [...]

Wrigley, the merger, and the comment letters…

Monday, April 28th, 2008

The big merger news this morning is that Mars plans to buy Wrigley (WWY) in an $23 billion deal that carries a hefty premium for Wrigley’s shareholders, given Friday’s closing price of $62.45. But what’s really interesting to me is what role a string of increasingly testy comment letters between the company and the SEC [...]

The silly season for perks…

Monday, April 21st, 2008

Here at footnoted, we’re all about better disclosure. But as with most of the other good things in life, there are certain times when there is simply too much of a good thing. Take the proxy statement filed by CVB Financial (CVBF) last week. In a footnote to the “all other compensation”, the bank disclosed [...]

Odds and ends…

Friday, March 28th, 2008

It’s been another one of those weeks here at footnoted, with so many filings that it’s been hard to pick and choose. So instead of just focusing on one or two, I thought I’d do a bit of “spring cleaning” and talk about some of the things that wound up in the footnoted net this [...]