SEC Comment Letter for STANDARD MANAGEMENT CORP (CIK 0000853971) — Jul 5, 2005
STANDARD MANAGEMENT CORP (CIK 0000853971)
Date: July 5, 2005 · CIK: 0000853971 · Accession: 0000000000-05-033935
AI Filing Summary & Sentiment
File numbers found in text: 000-20882
Letter
Via Facsimile and U.S. Mail Mail Stop 03-09 November 17, 2004 Mr. Stephen M. Coons Executive Vice President and General Counsel Standard Management Corporation 10689 North Pennsylvania Indianapolis, IN 46280
Re: Standard Management Corporation Form 8-K filed November 1, 2004 File No. 000-20882
Dear Mr. Coons:
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. 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 filing;
* 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.
2. Please amend your filing to provide a letter from the former accountant that has been revised to also address the statement you made about them in the second sentence of the first paragraph, as they would presumably have a basis to agree or disagree with your statement that they declined to stand for re-election effective October 27, 2004.
Please file your supplemental response and amendment via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. Direct any questions regarding the above to me at (202) 942-2902.
Sincerely,
Oscar M. Young, Jr.
Senior Accountant
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Show Raw Text
<DOCUMENT>
<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>
Via Facsimile and U.S. Mail
Mail Stop 03-09
November 17, 2004
Mr. Stephen M. Coons
Executive Vice President and General Counsel
Standard Management Corporation
10689 North Pennsylvania
Indianapolis, IN 46280
Re: Standard Management Corporation
Form 8-K filed November 1, 2004
File No. 000-20882
Dear Mr. Coons:
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. 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 filing;
* 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.
2. Please amend your filing to provide a letter from the former
accountant that has been revised to also address the statement
you
made about them in the second sentence of the first paragraph, as
they would presumably have a basis to agree or disagree with your
statement that they declined to stand for re-election effective
October 27, 2004.
Please file your supplemental response and amendment via
EDGAR
in response to these comments within 5 business days of the date
of
this letter. Please note that if you require longer than 5
business
days to respond, you should contact the staff immediately to
request
additional time. Direct any questions regarding the above to me
at
(202) 942-2902.
Sincerely,
Oscar M. Young, Jr.
Senior Accountant
??
??
??
??
Mr. Stephen M. Coons
Standard Management Corporation
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</TEXT>
</DOCUMENT>