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) — Feb 17, 2011
MORGAN STANLEY (MS, MS-PA, MS-PE, MS-PF, MS-PI, MS-PK, MS-PL, MS-PO, MS-PP, MS-PQ) (CIK 0000895421)
Date: Feb. 17, 2011 · CIK: 0000895421 · Accession: 0000000000-11-010565
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-11758
Letter
February 17, 2011 Ruth Porat Chief Financial Officer Morgan Stanley 1585 Broadway New York, NY 10036
Re: Morgan Stanley Form 10-Q for Quarterly Period Ended September 30, 2010 Filed November 8, 2010 File No. 001-11758
Dear Ms. Porat: We have reviewed your response letter date d February 14, 2011 and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments.
Ruth Porat Morgan Stanley February 17, 2011 Page 2
Form 10-Q for the quarterly period ended September 30, 2010
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
Liquidity and Capital Resource, page 118
1. We note your response to our prior comment tw o. Please clarify for us whether any third parties, including any clearing ba nk, hold liens on securities th at have been reversed to the company on an overnight basis by its subsidia ries. To the extent these liens exist, tell us how you concluded it would be appropriate to include these a ssets in your Global Liquidity Reserve.
You may contact Jennifer Moni ck, Senior Staff Accountan t, at 202-551-3295 or me at 202-551-3438 if you have questions. Sincerely,
Robert Telewicz Senior Staff Accountant
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February 17, 2011 Ruth Porat Chief Financial Officer Morgan Stanley 1585 Broadway New York, NY 10036 Re: Morgan Stanley Form 10-Q for Quarterly Period Ended September 30, 2010 Filed November 8, 2010 File No. 001-11758 Dear Ms. Porat: We have reviewed your response letter date d February 14, 2011 and have the following additional comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Ruth Porat Morgan Stanley February 17, 2011 Page 2 Form 10-Q for the quarterly period ended September 30, 2010 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations Liquidity and Capital Resource, page 118 1. We note your response to our prior comment tw o. Please clarify for us whether any third parties, including any clearing ba nk, hold liens on securities th at have been reversed to the company on an overnight basis by its subsidia ries. To the extent these liens exist, tell us how you concluded it would be appropriate to include these a ssets in your Global Liquidity Reserve. You may contact Jennifer Moni ck, Senior Staff Accountan t, at 202-551-3295 or me at 202-551-3438 if you have questions. Sincerely, Robert Telewicz Senior Staff Accountant