SEC Comment Letter for DEFAULT PROOF CREDIT CARD SYSTEM — Jul 18, 2005
DEFAULT PROOF CREDIT CARD SYSTEM INC /FL/ (CIK 0000803260)
Date: July 18, 2005 · CIK: 0000803260 · Accession: 0000000000-05-036749
AI Filing Summary & Sentiment
File numbers found in text: 000-24444
Referenced dates: May 10, 2005
Letter
July 18, Mail Stop 4561 Charles A. Menendez 1545 Miller Road Coral Gables, FL 33146
Re: Default Proof Credit Card System, Inc. Form 10- KSB/A for the year ended December 31, 2004 File No. 000-24444
Dear Mr. Menendez:
We have reviewed your response letter dated May 10, 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-KSB/A
Item 8 Financial Statements
Report of Independent Registered Public Accounting Firm
1. We noted that your report of the independent registered public accounting firm was not signed. Tell us how you considered Item of Regulation S-T. Confirm that a manually signed audit opinion has been received from the independent registered public accounting firm.
Note 10 - Due to a Related Party
2. We have read and considered your response to comment 3 and remain unclear how your accounting treatment complies with the guidance in APB 26 footnote 1. Accordingly, it appears that you should have shown the forgiveness of debt by the related party as a reduction of equity.
* * * *
As appropriate, please amend your filing respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. 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 amendment and 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
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
July 18,
2005
Mail Stop 4561
Charles A. Menendez
1545 Miller Road
Coral Gables, FL 33146
Re: Default Proof Credit Card System, Inc.
Form 10- KSB/A for the year ended December 31, 2004
File No. 000-24444
Dear Mr. Menendez:
We have reviewed your response letter dated May 10, 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-KSB/A
Item 8 Financial Statements
Report of Independent Registered Public Accounting Firm
1. We noted that your report of the independent registered public
accounting firm was not signed. Tell us how you considered Item
302
of Regulation S-T. Confirm that a manually signed audit opinion
has
been received from the independent registered public accounting
firm.
Note 10 - Due to a Related Party
2. We have read and considered your response to comment 3 and
remain
unclear how your accounting treatment complies with the guidance
in
APB 26 footnote 1. Accordingly, it appears that you should have
shown the forgiveness of debt by the related party as a reduction
of
equity.
* * * *
As appropriate, please amend your filing respond to these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information. 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 amendment and 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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Charles A. Menendez
Default Proof Credit Card System, Inc.
July 18, 2005
Page 1
</TEXT>
</DOCUMENT>