SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for MC SHIPPING INC (CIK 0000847831) — Mar 28, 2005

MC SHIPPING INC (CIK 0000847831)
Date: March 28, 2005 · CIK: 0000847831 · Accession: 0000000000-05-014322

AI Filing Summary & Sentiment

Date
March 28, 2005
Author
Effie Simpson
Form
UPLOAD
Company
MC SHIPPING INC (CIK 0000847831)

Letter

March 28, 2005 Zip+4 Code: 20549-0305 Via Fax & U.S. Mail Mr. Anthony S. Crawford Chief Executive Officer MC Shipping, Inc. Richmond House 12 Par-La-Ville Road Hamilton HM CX, Bermuda

Re: Form 8-K dated March 22, 2005 File No.: 1-10231

Dear Mr. Crawford:

We have reviewed your filing and have the following 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.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

1. Amend Item 4 of Form 8-K to cover the interim period from the date of the last audited financial statements to the date of dismissal. See Item 304(a)(1)(iv) of Regulation S-K.

2. Include a letter from the former accountants, indicating whether or not they agree with your disclosures in the Form 8-K, and file it as an Exhibit 16.

Engagement of new accountant:

3. When you engage a new accountant, please report the engagement in a Form 8-K and comply with the requirements of Regulation S-K Item 304 (a)(2). In making any disclosures about consultations with your new accountants, please ensure you disclose any consultations up through the date of engagement. 4. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the disclosure in the filings; * staff comments or changes to 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 * the company 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.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.

Please file your supplemental response and amendment via Edgar in response to these comments within five business days of the date of this letter. Please note that if you require longer than five business days to respond, you should contact the staff immediately to request additional time.

You may contact Effie Simpson at (202) 942-2838 or Bob Benton, Senior Accountant, at (202) 942-1811 if you have any questions.

Sincerely,
Effie Simpson
Staff Accountant
??

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

								March 28, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Anthony S. Crawford
Chief Executive Officer
MC Shipping, Inc.
Richmond House
12 Par-La-Ville Road
Hamilton HM CX, Bermuda

	Re:	Form 8-K dated March 22, 2005
      File No.: 1-10231

Dear Mr. Crawford:

We have reviewed your filing and have the following 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.

Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

1. Amend Item 4 of Form 8-K to cover the interim period from the
date
of the last audited financial statements to the date of dismissal.
See Item 304(a)(1)(iv) of Regulation S-K.

2. Include a letter from the former accountants, indicating
whether
or not they agree with your disclosures in the Form 8-K, and file
it
as an Exhibit 16.

Engagement of new accountant:

3. When you engage a new accountant, please report the engagement
in
a Form 8-K and comply with the requirements of Regulation S-K Item
304 (a)(2).  In making any disclosures about consultations with
your
new accountants, please ensure you disclose any consultations up
through the date of engagement.
4. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to 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
* the company 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please file your supplemental response and amendment via Edgar in
response to these comments within five business days of the date
of
this letter.  Please note that if you require longer than five
business days to respond, you should contact the staff immediately
to
request additional time.

You may contact Effie Simpson at (202) 942-2838 or Bob Benton,
Senior
Accountant, at (202) 942-1811 if you have any questions.

								Sincerely,

								Effie Simpson
								Staff Accountant
??

??

??

??

Mr. Anthony S. Crawford
MC Shipping, Inc.
March 28, 2005
Page 1

</TEXT>
</DOCUMENT>