SEC Company Response from CCA INDUSTRIES INC (CIK 0000721447) — Nov 14, 2005
CCA INDUSTRIES INC (CIK 0000721447)
Date: Nov. 14, 2005 · CIK: 0000721447 · Accession: 0001317273-05-000037
AI Filing Summary & Sentiment
Referenced dates: October 27, 2005
Letter
Division of Cooperative Finance US Securities and Exchange Commission 450 Fifth Street Washington,D.C.
Dear Mr. Cash:
Thank you for your letter dated October 27, 2005 regarding our August 31, 2005 10Q.
1) We have explained to our staff that the disclosure relating to the American Jobs Creation Act of 2004 pertaining to unrepariated earnings of Foreign subsidiaries is not applicable to CCA. We will delete the disclosure in the last three paragraphs of Note 3 in our amended 10Q.
2) We will delete the pro-forma number for the third quarter of 2005 from the footnote and only include that information in our MD&A, as we believe it is important to not mislead the public and to give them a valid basis of comparing our operations from year to year.
3) We will revise our disclosure to state that our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were effective as of August 31, 2005. We will correct the typing error of the date in the first paragraph of our Section 906 certificate and have identified the applicable report required by Section 302 in our corrected August 31, 2005 10Q.
Please let us know if there is anything else you wish us to explain or amend in our 10Q. If not, we will amend our 10Q as we have described in our letters and resubmit it for your approval. We will also attend to all of your suggestions in all of our future filings.
Very truly yours,
John Bingman
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CCA INDUSTRIES, INC.
200 MURRAY HILL
PARKWAY
EAST RUTHERFORD, NJ
November 8, 2004
Mr. John Cash
Accounting Branch Chief
Division of Cooperative Finance
US Securities and Exchange Commission
450 Fifth Street
Washington,D.C.
Dear Mr. Cash:
Thank you for your letter dated October 27, 2005 regarding
our August 31, 2005 10Q.
1) We have explained to our staff that the disclosure
relating to the American Jobs Creation Act of 2004 pertaining to unrepariated
earnings of Foreign subsidiaries is not applicable to CCA. We will delete the
disclosure in the last three paragraphs of Note 3 in our amended 10Q.
2) We will delete the pro-forma number for the third quarter
of 2005 from the footnote and only include that information in our MD&A, as
we believe it is important to not mislead the public and to give them a valid
basis of comparing our operations from year to year.
3) We will revise our disclosure to state that our Chief
Executive Officer and Chief Financial Officer concluded that our disclosure
controls and procedures were effective as of August 31, 2005. We will correct
the typing error of the date in the first paragraph of our Section 906
certificate and have identified the applicable report required by Section 302
in our corrected August 31, 2005 10Q.
Please let us know if there is anything else you wish us to
explain or amend in our 10Q. If not, we will amend our 10Q as we have described
in our letters and resubmit it for your approval. We will also attend to all of
your suggestions in all of our future filings.
Very truly yours,
John Bingman
Chief Financial Officer