SEC Comment Letter for CHAUS BERNARD INC (CIK 0000793983) — Mar 22, 2005
CHAUS BERNARD INC (CIK 0000793983)
Date: March 22, 2005 · CIK: 0000793983 · Accession: 0000000000-05-013253
AI Filing Summary & Sentiment
Referenced dates: March 14, 2005
Letter
March 22, 2005 By Facsimile and U.S. Mail Mr. Barton Heminover Chief Financial Officer Bernard Chaus, Inc. 530 Seventh Avenue New York, New York 10018
RE: Form 10-K, for the year ended June 30, 2004 Filed September 28, 2004
Dear Mr. Heminover:
We have reviewed your responses in your letter dated March 14, 2005 and have the following additional comment.
We welcome any questions you may have about our comment or on 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 YEAR ENDED JUNE 30, 2004
Credit Terms, page F-7
1. We read your response to comment 5. Please tell us how the transferee has assumed the full risk of collection, since you do not receive payments from the transferee until they receive payments from your customers. It appears that you have received a beneficial interest in the factored receivables. Also, tell us the timing of when you record the sale of the receivables and when you consider the transaction for the transfer of the receivables to be complete. See paragraphs 9-12 of SFAS 140.
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please ensure the response letter provides any requested supplemental information. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment.
If you have any questions regarding this comment, please direct them to Anthony Watson, Staff Accountant, at (202) 942-7781 or, in his absence, to Donna Di Silvio at (202) 942-1852, or me at (202) 942- 2905. Sincerely,
George F. Ohsiek, Jr. Branch Chief ??
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March 22, 2005 Page 1
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 3-8 March 22, 2005 By Facsimile and U.S. Mail Mr. Barton Heminover Chief Financial Officer Bernard Chaus, Inc. 530 Seventh Avenue New York, New York 10018 RE: Form 10-K, for the year ended June 30, 2004 Filed September 28, 2004 Dear Mr. Heminover: We have reviewed your responses in your letter dated March 14, 2005 and have the following additional comment. We welcome any questions you may have about our comment or on 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 YEAR ENDED JUNE 30, 2004 Credit Terms, page F-7 1. We read your response to comment 5. Please tell us how the transferee has assumed the full risk of collection, since you do not receive payments from the transferee until they receive payments from your customers. It appears that you have received a beneficial interest in the factored receivables. Also, tell us the timing of when you record the sale of the receivables and when you consider the transaction for the transfer of the receivables to be complete. See paragraphs 9-12 of SFAS 140. As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please ensure the response letter provides any requested supplemental information. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. If you have any questions regarding this comment, please direct them to Anthony Watson, Staff Accountant, at (202) 942-7781 or, in his absence, to Donna Di Silvio at (202) 942-1852, or me at (202) 942- 2905. Sincerely, George F. Ohsiek, Jr. Branch Chief ?? ?? ?? ?? March 22, 2005 Page 1 </TEXT> </DOCUMENT>