SEC Comment Letter for JPMORGAN CHASE & CO (JPM, AMJB, VYLD, JPM-PC, JPM-PD, JPM-PJ, JPM-PK, JPM-PL, JPM-PM) (CIK 0000019617) (JPM) — May 23, 2006
JPMORGAN CHASE & CO (JPM, AMJB, VYLD, JPM-PC, JPM-PD, JPM-PJ, JPM-PK, JPM-PL, JPM-PM) (CIK 0000019617)
Date: May 23, 2006 · CIK: 0000019617 · Accession: 0000000000-06-024409
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 11, 2006, May 4, 2006
Letter
Mail Stop 4561 May 23, 2006 Mr. Michael J. Cavanagh Chief Financial Officer JPMorgan Chase & Co. 270 Park Avenue New York, NY 10017
RE: JPMorgan Chase & Co. Form 10-K for the Fiscal Ye ar Ended December 31, 2005 Filed March 9, 2006 File No. 1-5805
Dear Mr. Cavanagh:
We have reviewed your supplemental re sponse letter dated May 4, 2006 and have the following comments.
Form 10-K for Fiscal Year Ended December 31, 2005
Consolidated Financial Statements
Statements of Cash Flows, page 90 1. We note in your response to comment one of our letter dated April 11, 2006 that you have historically classified cash flows related to loan activities as investing activities, regardless of whether a loan is classified as held-for-sale at inception or subsequent to origination. Paragrap h 9 of SFAS 102 requires that cash flows resulting from originations, acquisitions a nd sales of loans should be classified as operating cash flows if those loans are acquired specifically for resale. Please amend your December 31, 2005 10-K and applicable Forms 10-Q to revise your Statements of Cash Flows to present as operating activities the cash flows related to the origination/purchase and sales/secu ritization of loans for which you had the intent to sell or securitize when the lo an was originated or purchased. If you do not believe this would result in a material change to your Statements of Cash Flows, please provide us with a comprehensive analysis of the impact, including the applicable gross and net cash flows.
Mr. Michael J. Cavanagh JPMorgan Chase & Co. May 23, 2006 Page 2 Note 26 – Accounting for derivative inst ruments and hedging ac tivities, page 123 2. We have reviewed your response to comment three of our letter dated April 11, 2006. Regarding cash flow hedges of short-term assets and liabilities that rollover or reprice, please tell us the defined ti me period over which you typically forecast interest receipts and payments.
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comm ents after reviewing your response to our comments.
You may contact Sharon Bl ume, Staff Accountant, at (202) 551-3474 or me at (202) 551-3449 if you have questions.
S i n c e r e l y ,
J o y c e S w e e n e y A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
Mail Stop 4561
May 23, 2006
Mr. Michael J. Cavanagh
Chief Financial Officer
JPMorgan Chase & Co.
270 Park Avenue
New York, NY 10017
RE: JPMorgan Chase & Co.
Form 10-K for the Fiscal Ye ar Ended December 31, 2005
Filed March 9, 2006
File No. 1-5805
Dear Mr. Cavanagh:
We have reviewed your supplemental re sponse letter dated May 4, 2006 and have
the following comments.
Form 10-K for Fiscal Year Ended December 31, 2005
Consolidated Financial Statements
Statements of Cash Flows, page 90
1. We note in your response to comment one of our letter dated April 11, 2006 that
you have historically classified cash flows related to loan activities as investing
activities, regardless of whether a loan is classified as held-for-sale at inception or
subsequent to origination. Paragrap h 9 of SFAS 102 requires that cash flows
resulting from originations, acquisitions a nd sales of loans should be classified as
operating cash flows if those loans are acquired specifically for resale. Please
amend your December 31, 2005 10-K and applicable Forms 10-Q to revise your Statements of Cash Flows to present as operating activities the cash flows related to the origination/purchase and sales/secu ritization of loans for which you had the
intent to sell or securitize when the lo an was originated or purchased. If you do
not believe this would result in a material change to your Statements of Cash Flows, please provide us with a comprehensive analysis of the impact, including the applicable gross and net cash flows.
Mr. Michael J. Cavanagh
JPMorgan Chase & Co.
May 23, 2006 Page 2
Note 26 – Accounting for derivative inst ruments and hedging ac tivities, page 123
2. We have reviewed your response to comment three of our letter dated April 11, 2006. Regarding cash flow hedges of short-term assets and liabilities that rollover or reprice, please tell us the defined ti me period over which you typically forecast
interest receipts and payments.
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comm ents after reviewing your response to our
comments.
You may contact Sharon Bl ume, Staff Accountant, at (202) 551-3474 or me at
(202) 551-3449 if you have questions.
S i n c e r e l y ,
J o y c e S w e e n e y
A c c o u n t i n g B r a n c h C h i e f