SEC Company Response from BHP Group Ltd (BHP, BHPLF) (CIK 0000811809) (BHP) — Mar 21, 2005
BHP Group Ltd (BHP, BHPLF) (CIK 0000811809)
Date: March 21, 2005 · CIK: 0000811809 · Accession: 0000950172-05-000893
AI Filing Summary & Sentiment
Referenced dates: March 17, 2005
Letter
By EDGAR and Hand Delivery United States Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549-0405 Attention: Ms. Gabrielle Maltis Staff Accountant
RE: BHP USA Retirement Savings Plan Savings Plan for Hourly-Rated Employees of BHP Copper Inc. Forms 8-K filed March 10, 2005 File No. 1-9526
Dear Ms. Maltis:
On behalf of BHP USA Retirement Savings Plan and Savings Plan for Hourly-Rated Employees of BHP Copper Inc. (the "Plans"), I am writing to respond to your letter dated March 17, 2005, with regard to the above-referenced filings.
In compliance with Item 4.01 of Form 8-K and Item 304(a)(3), and in accordance with the SEC's comment, each of the Plans has today filed an amendment to its Form 8-K filing a letter from the former auditor to each Plan indicating the former auditor's agreement or disagreement with the statements in the Form 8-K filing as they pertain to the former auditor.
KPMG, the former auditor of both Plans, reviewed each of the Form 8-K/As before filing. None of the disclosures contained in the original Form 8-Ks has been revised.
Each of the Plans acknowledges that:
o each Plan is responsible for the adequacy and accuracy of the disclosure in its filings;
o staff comments or changes in disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and
o the Plan may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Yours truly,
/s/ Howard Spiegel Howard Spiegel
cc: Robert H. Williams Skadden, Arps, Slate, Meagher & Flom (International)
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March 21, 2005
By EDGAR and Hand Delivery
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549-0405
Attention: Ms. Gabrielle Maltis
Staff Accountant
RE: BHP USA Retirement Savings Plan
Savings Plan for Hourly-Rated Employees of
BHP Copper Inc.
Forms 8-K filed March 10, 2005
File No. 1-9526
Dear Ms. Maltis:
On behalf of BHP USA Retirement Savings Plan and Savings Plan for
Hourly-Rated Employees of BHP Copper Inc. (the "Plans"), I am writing to
respond to your letter dated March 17, 2005, with regard to the
above-referenced filings.
In compliance with Item 4.01 of Form 8-K and Item 304(a)(3), and in
accordance with the SEC's comment, each of the Plans has today filed an
amendment to its Form 8-K filing a letter from the former auditor to each Plan
indicating the former auditor's agreement or disagreement with the statements
in the Form 8-K filing as they pertain to the former auditor.
KPMG, the former auditor of both Plans, reviewed each of the Form
8-K/As before filing. None of the disclosures contained in the original Form
8-Ks has been revised.
Each of the Plans acknowledges that:
o each Plan is responsible for the adequacy and accuracy of the disclosure
in its filings;
o staff comments or changes in disclosure in response to staff comments in
the filings reviewed by the staff do not foreclose the Commission from
taking any action with respect to the filing; and
o the Plan may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
Yours truly,
/s/ Howard Spiegel
Howard Spiegel
cc: Robert H. Williams
Skadden, Arps, Slate, Meagher & Flom (International)
</TEXT>
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