SEC Comment Letter for WELLS FARGO & (WFC) — May 11, 2006
WELLS FARGO & COMPANY/MN (WFC, WFCNP, WFC-PA, WFC-PC, WFC-PD, WFC-PL, WFC-PY, WFC-PZ) (CIK 0000072971)
Date: May 11, 2006 · CIK: 0000072971 · Accession: 0000000000-06-022488
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-02979
Referenced dates: December 9, 2006
Letter
March 2, 2006 By U.S. Mail and facsimile to (415) 975-6871. Howard I. Atkins Senior Executive Vice Presiden t and Chief Financial Officer Wells Fargo & Company 420 Montgomery Street San Francisco, CA 94104
Re: Wells Fargo & Company Form 10-K for the Fiscal Year Ended December 31, 2004 Form 10-Q for the Fiscal Quarters Ended March 31, 2005, June 30, 2005 and September 30, 2005 File No. 001-02979
Dear Mr. Atkins:
We have reviewed your response filed on January 26, 2006 and have the following additional comments. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with supplemental information so we may better understand your response. After review ing this information, we may or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the fiscal year ended December 31, 2004:
General 1. We refer you to prior comments three and four in our previous comment letter dated December 9, 2006. Please quantify the approximate amounts of annual revenues and expenses associated with th e customer ties and other contacts that
Howard I. Atkins Wells Fargo & Company March 2, 2006 Page 2 you identified in your January 13, 2006 response. Your response should discuss whether you believe these contacts are ma terial to you, and the reasons you do not believe the accounts you discussed in your January 13 response constitute a material investment risk to your secur ity holders. You should also discuss whether you believe the other contacts you identified in your January 13 letter constitute a material investment risk to your security holder s, and the reasons underlying your conclusion. 2. Please address the qualitative factors unde rlying your assessment. For example, you did not address the potenti al impact of the investor sentiment expressed by the legislation identified in prior comme nt four, or explain how the compliance efforts you discussed affect your conclusi on as to whether or not your contacts with Iran, Sudan and Syria are material to you or constitute a material investment risk to your security holders.
* * * * *
As appropriate, please provide us with your response within 10 business days or tell us when you will provide us with a respons e. Please furnish a cover letter that keys your response to our comments and provides any requested supplemental information. Please understand that we may have additiona l comments after reviewing your responses to our comments.
You may contact Rebekah Moore at (202) 551-3463, James Lopez at (202) 551- 3536, or me at (202) 551-3494 if you have questions.
Sincerely,
Kevin W. Vaughn
Branch Chief
Show Raw Text
Mail Stop 4561 March 2, 2006 By U.S. Mail and facsimile to (415) 975-6871. Howard I. Atkins Senior Executive Vice Presiden t and Chief Financial Officer Wells Fargo & Company 420 Montgomery Street San Francisco, CA 94104 Re: Wells Fargo & Company Form 10-K for the Fiscal Year Ended December 31, 2004 Form 10-Q for the Fiscal Quarters Ended March 31, 2005, June 30, 2005 and September 30, 2005 File No. 001-02979 Dear Mr. Atkins: We have reviewed your response filed on January 26, 2006 and have the following additional comments. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with supplemental information so we may better understand your response. After review ing this information, we may or may not raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the fiscal year ended December 31, 2004: General 1. We refer you to prior comments three and four in our previous comment letter dated December 9, 2006. Please quantify the approximate amounts of annual revenues and expenses associated with th e customer ties and other contacts that Howard I. Atkins Wells Fargo & Company March 2, 2006 Page 2 you identified in your January 13, 2006 response. Your response should discuss whether you believe these contacts are ma terial to you, and the reasons you do not believe the accounts you discussed in your January 13 response constitute a material investment risk to your secur ity holders. You should also discuss whether you believe the other contacts you identified in your January 13 letter constitute a material investment risk to your security holder s, and the reasons underlying your conclusion. 2. Please address the qualitative factors unde rlying your assessment. For example, you did not address the potenti al impact of the investor sentiment expressed by the legislation identified in prior comme nt four, or explain how the compliance efforts you discussed affect your conclusi on as to whether or not your contacts with Iran, Sudan and Syria are material to you or constitute a material investment risk to your security holders. * * * * * As appropriate, please provide us with your response within 10 business days or tell us when you will provide us with a respons e. Please furnish a cover letter that keys your response to our comments and provides any requested supplemental information. Please understand that we may have additiona l comments after reviewing your responses to our comments. You may contact Rebekah Moore at (202) 551-3463, James Lopez at (202) 551- 3536, or me at (202) 551-3494 if you have questions. Sincerely, Kevin W. Vaughn Branch Chief