SEC Comment Letter for IDS MANAGED FUTURES L P (CIK 0000809061) — Jul 7, 2005
IDS MANAGED FUTURES L P (CIK 0000809061)
Date: July 7, 2005 · CIK: 0000809061 · Accession: 0000000000-05-034651
AI Filing Summary & Sentiment
Referenced dates: June 28, 2005
Letter
Mail Stop 4561 July 7, 2005 Shaun D. O`Brien Chief Financial Officer IDS Managed Futures, L.P. 233 South Wacker Drive, Suite 2300 Chicago, IL 60606
Re: IDS Managed Futures, L.P. Form 10-K/A for the fiscal year ended December 31, 2004 Filed July 1, 2005 File No. 0-16515
Dear Mr. O`Brien:
We have reviewed your first response letter dated June 28, and have the following additional comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Form 10-K/A For the Fiscal Year Ended December 31, 2004
Signatures
1. It appears that you have not updated your signatures from the March 29, 2005 date in connection with your current filing of Form 10-K/A. In future filings, please update signatures and certifications in Exhibit 31 when making an amended filing.
Note 6 - Investments in Other Commodity Pool
2. We note your response to prior comment 3. Please clarify for us why you did not present separate financial statements for IDS Managed Fund, LLC as of the same dates and for the same periods as those provided for IDS Managed Futures, L.P. or amend your filing to provide such information. Reference is made to Rule 3-09 (b) of Regulation S-X.
As appropriate, please amend your filing and 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 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 Howard Efron, Staff Accountant, at (202) 551- 3439 or me at (202) 551-3403 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Steven Jacobs
Branch Chief
Show Raw Text
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Mail Stop 4561
July 7, 2005
Shaun D. O`Brien
Chief Financial Officer
IDS Managed Futures, L.P.
233 South Wacker Drive, Suite 2300
Chicago, IL 60606
Re: IDS Managed Futures, L.P.
Form 10-K/A for the fiscal year ended December 31, 2004
Filed July 1, 2005
File No. 0-16515
Dear Mr. O`Brien:
We have reviewed your first response letter dated June 28,
2005
and have the following additional comments. Where indicated, we
think you should revise your document in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary. Please be
as
detailed as necessary in your explanation. In some of our
comments,
we may ask you to provide us with supplemental information so we
may
better understand your disclosure. After reviewing this
information,
we may or may not raise additional comments.
Form 10-K/A For the Fiscal Year Ended December 31, 2004
Signatures
1. It appears that you have not updated your signatures from the
March 29, 2005 date in connection with your current filing of Form
10-K/A. In future filings, please update signatures and
certifications in Exhibit 31 when making an amended filing.
Note 6 - Investments in Other Commodity Pool
2. We note your response to prior comment 3. Please clarify for
us
why you did not present separate financial statements for IDS
Managed
Fund, LLC as of the same dates and for the same periods as those
provided for IDS Managed Futures, L.P. or amend your filing to
provide such information. Reference is made to Rule 3-09 (b) of
Regulation S-X.
As appropriate, please amend your filing and 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 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 Howard Efron, Staff Accountant, at (202) 551-
3439 or me at (202) 551-3403 if you have questions regarding
comments
on the financial statements and related matters.
Sincerely,
Steven Jacobs
Branch Chief
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Mr. O'Brien
IDS Managed Futures, L.P.
July 7, 2005
Page 2
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