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) — Jul 20, 2006
JPMORGAN CHASE & CO (JPM, AMJB, VYLD, JPM-PC, JPM-PD, JPM-PJ, JPM-PK, JPM-PL, JPM-PM) (CIK 0000019617)
Date: July 20, 2006 · CIK: 0000019617 · Accession: 0000000000-06-033815
AI Filing Summary & Sentiment
Reasoning
Referenced dates: July 13, 2006, May 23, 2006
Letter
Mail Stop 4561 July 19, 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 response letter dated July 13, 2006 and have the following comments.
Form 10-K for Fiscal Year Ended December 31, 2005
Management’s Discussion and Analysis
Liquidity risk management, page 61 1. In future filings please explain why you had negative cash flows from operating and investing activities for the pe riods ending December 31, 2005 and 2004. Provide us with your proposed future disclosure.
Mr. Michael J. Cavanagh JPMorgan Chase & Co. July 20, 2006 Page 2 Consolidated Financial Statements
Statements of Cash Flows, page 90 2. We have reviewed the supplemental information provided in response to comment one of our letter dated May 23, 2006. As the impact of the net cash flows associated with lo ans you originated/purchased with the intent to sell/securitize appears quantitatively and qua litatively material to cash flows from operating and investing activities, pl ease amend your December 31, 2005 10-K and applicable Forms 10-Q to restate your Statements of Cash Flows to present these cash flows as operating activities. Please include a financial statement footnote describing and quantifying the correction of an error. 3. We note your disclosure on page 108 rega rding accounting policies for retained interests in securitized loans. Please tell us how you classify cash flows related to retained interests in secu ritized and wholesale loan s and your basis for that treatment. In your response, please distinguish between the retained interests classified as other assets, trading securi ties, and available-for-sale securities. Describe how you separate the actual amount of cash flows from the non-cash exchanges related to the retained intere sts for reporting on your Statements of Cash Flows.
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
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Mail Stop 4561
July 19, 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 response letter dated July 13, 2006 and
have the following comments.
Form 10-K for Fiscal Year Ended December 31, 2005
Management’s Discussion and Analysis
Liquidity risk management, page 61
1. In future filings please explain why you had negative cash flows from operating
and investing activities for the pe riods ending December 31, 2005 and 2004.
Provide us with your proposed future disclosure.
Mr. Michael J. Cavanagh
JPMorgan Chase & Co.
July 20, 2006 Page 2
Consolidated Financial Statements
Statements of Cash Flows, page 90
2. We have reviewed the supplemental information provided in response to
comment one of our letter dated May 23, 2006. As the impact of the net cash flows associated with lo ans you originated/purchased with the intent to
sell/securitize appears quantitatively and qua litatively material to cash flows from
operating and investing activities, pl ease amend your December 31, 2005 10-K
and applicable Forms 10-Q to restate your Statements of Cash Flows to present
these cash flows as operating activities. Please include a financial statement
footnote describing and quantifying the correction of an error.
3. We note your disclosure on page 108 rega rding accounting policies for retained
interests in securitized loans. Please tell us how you classify cash flows related to
retained interests in secu ritized and wholesale loan s and your basis for that
treatment. In your response, please distinguish between the retained interests
classified as other assets, trading securi ties, and available-for-sale securities.
Describe how you separate the actual amount of cash flows from the non-cash
exchanges related to the retained intere sts for reporting on your Statements of
Cash Flows.
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