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SEC Comment Letter for MORGAN STANLEY (MS, MS-PA, MS-PE, MS-PF, MS-PI, MS-PK, MS-PL, MS-PO, MS-PP, MS-PQ) (CIK 0000895421) (MS) — May 11, 2010

MORGAN STANLEY (MS, MS-PA, MS-PE, MS-PF, MS-PI, MS-PK, MS-PL, MS-PO, MS-PP, MS-PQ) (CIK 0000895421)
Date: May 11, 2010 · CIK: 0000895421 · Accession: 0000000000-10-025864

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: May 6, 2010

Date
May 11, 2010
Author
Not clearly detected
Form
UPLOAD
Company
MORGAN STANLEY (MS, MS-PA, MS-PE, MS-PF, MS-PI, MS-PK, MS-PL, MS-PO, MS-PP, MS-PQ) (CIK 0000895421)

Letter

Mail Stop 3010 May 11, 2010

VIA U.S. MAIL AND FAX (212) 507-3961

Ruth Porat Chief Financial Officer Morgan Stanley 1585 Broadway New York, NY 10036 Dear Ms. Porat: We have reviewed your response letter dated May 6, 2010 and have the following additional comment. If you disagree with our comment, we will consider your explanation as to why our comment is not applic able. Please be as detailed as necessary in your explanation. Please understand that the purpose of our re view 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 comment or on any other aspect of our review. Feel free to call me at the telephone number listed at the end of this letter. 1. We note your response to our prior comment one and your disclosure in the Form 10-Q for the quarter ended March 31, 2010. We note you describe your accounting policy for repurchase and s ecurities lending transactions as generally being treated as collater alized financings. In fu ture filings, please make an unqualified statement as to how you have accounted for these transactions. To the extent you have any deviations from your accounting policy, please explain and quantify these deviations in your disclosure.

Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please s ubmit your response letter on EDGAR. Please contact me at (202) 551-3498 if you have any questions. S i n c e r e l y , Linda van Doorn Senior Assistant Chief Accountant

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Mail Stop 3010
      May 11, 2010

VIA U.S. MAIL AND FAX (212) 507-3961

 Ruth Porat Chief Financial Officer Morgan Stanley 1585 Broadway New York, NY  10036
Dear Ms. Porat:
 We have reviewed your response letter dated May 6, 2010 and have the following
additional comment.  If you disagree with our comment, we will consider your
explanation as to why our comment is not applic able.  Please be as detailed as necessary
in your explanation.
 Please understand that the purpose of our re view 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  comment or on any other aspect of our
review.  Feel free to call me at the telephone  number listed at the end of this letter.
 1. We note your response to our prior comment  one and your disclosure in the Form
10-Q for the quarter ended March 31, 2010.  We note you describe your
accounting policy for repurchase and s ecurities lending transactions as
generally  being treated as collater alized financings.  In fu ture filings, please make
an unqualified statement as to how you have accounted for these transactions.  To the extent you have any deviations from your accounting policy, please explain
and quantify these deviations in your disclosure.

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please s ubmit your response letter on EDGAR.  Please
contact me at (202) 551-3498 if you have any questions.
      S i n c e r e l y ,
Linda van Doorn Senior Assistant Chief Accountant