SEC Comment Letter for CAPSTEAD MORTGAGE CORP (CIK 0000766701) — Oct 11, 2005
CAPSTEAD MORTGAGE CORP (CIK 0000766701)
Date: Oct. 11, 2005 · CIK: 0000766701 · Accession: 0000000000-05-052090
AI Filing Summary & Sentiment
File numbers found in text: 001-08896
Referenced dates: August 26, 2005
Letter
October 11, Mail Stop 4561 Andrew Jacobs 8401 North Central Expressway, Suite 800 Dallas, TX 75225
Re: Capstead Mortgage Corporation Form 10-K for the year ended December 31, 2004 File No. 001-08896
Dear Mr. Jacobs:
We have reviewed your response letter dated August 26, 2005 and have the following additional comments. As previously stated, these comments require amendment to the referenced filings previously filed with the Commission.
Form 10-K
Exhibit 13
Management`s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 38 1. We have read and considered your response to comment 4(a). We continue to believe the use of operating income and operating income per share is confusingly similar to other measures calculated under GAAP. As such, please revise future filings accordingly to label this measure in a manner that is dissimilar to descriptions used under GAAP. 2. In reference to your response to comment 4(b), please revise future filings to explain the reasons why management believes this non-GAAP financial measure provides useful information to investors regarding the Company`s operating performance. Your current disclosure that operating income is used to determine the funds available for reinvestment or distribution indicates that you are using this as a measure of your liquidity. Also tell us what consideration was given to disclosing this non-GAAP information separately from the other GAAP information included in your Results of Operations table under a heading clearly labeled as "Other Data". * * * *
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Yolanda Crittendon, Staff Accountant, at (202) 551-3472 or the undersigned at (202) 551-3413 if you have questions.
Sincerely,
Cicely Luckey
Branch Chief
Show Raw Text
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<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>
October 11,
2005
Mail Stop 4561
Andrew Jacobs
8401 North Central Expressway, Suite 800
Dallas, TX 75225
Re: Capstead Mortgage Corporation
Form 10-K for the year ended December 31, 2004
File No. 001-08896
Dear Mr. Jacobs:
We have reviewed your response letter dated August 26, 2005
and
have the following additional comments. As previously stated,
these
comments require amendment to the referenced filings previously
filed
with the Commission.
Form 10-K
Exhibit 13
Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations, page 38
1. We have read and considered your response to comment 4(a). We
continue to believe the use of operating income and operating
income
per share is confusingly similar to other measures calculated
under
GAAP. As such, please revise future filings accordingly to label
this measure in a manner that is dissimilar to descriptions used
under GAAP.
2. In reference to your response to comment 4(b), please revise
future filings to explain the reasons why management believes this
non-GAAP financial measure provides useful information to
investors
regarding the Company`s operating performance. Your current
disclosure that operating income is used to determine the funds
available for reinvestment or distribution indicates that you are
using this as a measure of your liquidity. Also tell us what
consideration was given to disclosing this non-GAAP information
separately from the other GAAP information included in your
Results
of Operations table under a heading clearly labeled as "Other
Data".
* * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Detailed cover letters greatly facilitate our review. Please file
your cover letter on EDGAR. Please understand that we may have
additional comments after reviewing your responses to our
comments.
You may contact Yolanda Crittendon, Staff Accountant, at
(202)
551-3472 or the undersigned at (202) 551-3413 if you have
questions.
Sincerely,
Cicely Luckey
Branch Chief
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Mr. Andrew Jacobs
Capstead Mortgage Corporation
October 11, 2005
Page 1
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