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) — Dec 13, 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: Dec. 13, 2011 · CIK: 0000895421 · Accession: 0000000000-11-071312
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-11758
Letter
December 12, 2011 Via E-mail Ruth Porat Executive Vice President and Chief Financial Officer Morgan Stanley 1585 Broadway New York, NY 10036 Re: Morgan Stanley Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 28, 2011 Form 10-Q for the Quarterly Period Ended March 31, 2011 Filed May 9, 2011 Form 10-Q for the Quarterly Period Ended June 30, 2011 Filed August 8, 2011 Form 10-Q for the Quarterly Period Ended March 31, 2011 Filed May 9, 2011 File No. 001-11758
Dear Ms. Porat:
We have reviewed your response letter da ted November 10, 2011 and are continuing to process your responses. In the inter im, we have an additional comment.
Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to the comment, we may have additional comments.
General
1. We have become aware through various ne ws reports that you may have accessed various Federal Reserve and Federal De posit Insurance Corporation sponsored funding programs during 2008 and 2009, including the Term Auction Facility (TAF), Commercial Paper Funding Facility (C PFF), Temporary Liquidity Guarantee Program (TLGP), the Primary Dealer Credit Facility (PDCF) and the Term Securities Lending Facility (TSLF). We note from your disclosures during these periods that you appear to disclose the participation in certain programs, including the TLGP and
Ruth Porat Morgan Stanley December 12, 2011 Page 2 the amounts of borrowing outstanding as of the balance sheet dates for that program, you disclose the existence and availability of certain other programs, such as the PDCF and TSLF, but you do not appear to ha ve provided quantified information as to the level or amounts of borrowings under th ese programs, and you do not provide any discussion about certain other pr ograms that were in existenc e at this time, such as the TAF and CPFF. To the extent that you had borrowings under any of these programs during those periods, please tell us ho w you concluded that quantitative and qualitative disclosure about your participation in these programs was not required. Additionally, please provide your analysis as to whether you believe that any participation in these programs constituted a form of federal financial assistance, such that additional disclosure may have been requ ired as to the effects of this assistance on your financial condition and results of ope rations pursuant to the guidance in FRC 501.06.c. Effects of Federal Financia l Assistance Upon Operations.
You may contact Staci Shannon at (202) 551-3374 or me at (202) 551-3494 if you have questions regarding comments on the fi nancial statements and related matters. Please contact Michael Seaman at (202) 551-3366 or Suzanne Hayes at (202) 551-3675 with any other questions. Sincerely,
/s/ Suzanne Hayes Suzanne Hayes Assistant Director
Show Raw Text
December 12, 2011 Via E-mail Ruth Porat Executive Vice President and Chief Financial Officer Morgan Stanley 1585 Broadway New York, NY 10036 Re: Morgan Stanley Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 28, 2011 Form 10-Q for the Quarterly Period Ended March 31, 2011 Filed May 9, 2011 Form 10-Q for the Quarterly Period Ended June 30, 2011 Filed August 8, 2011 Form 10-Q for the Quarterly Period Ended March 31, 2011 Filed May 9, 2011 File No. 001-11758 Dear Ms. Porat: We have reviewed your response letter da ted November 10, 2011 and are continuing to process your responses. In the inter im, we have an additional comment. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to the comment, we may have additional comments. General 1. We have become aware through various ne ws reports that you may have accessed various Federal Reserve and Federal De posit Insurance Corporation sponsored funding programs during 2008 and 2009, including the Term Auction Facility (TAF), Commercial Paper Funding Facility (C PFF), Temporary Liquidity Guarantee Program (TLGP), the Primary Dealer Credit Facility (PDCF) and the Term Securities Lending Facility (TSLF). We note from your disclosures during these periods that you appear to disclose the participation in certain programs, including the TLGP and Ruth Porat Morgan Stanley December 12, 2011 Page 2 the amounts of borrowing outstanding as of the balance sheet dates for that program, you disclose the existence and availability of certain other programs, such as the PDCF and TSLF, but you do not appear to ha ve provided quantified information as to the level or amounts of borrowings under th ese programs, and you do not provide any discussion about certain other pr ograms that were in existenc e at this time, such as the TAF and CPFF. To the extent that you had borrowings under any of these programs during those periods, please tell us ho w you concluded that quantitative and qualitative disclosure about your participation in these programs was not required. Additionally, please provide your analysis as to whether you believe that any participation in these programs constituted a form of federal financial assistance, such that additional disclosure may have been requ ired as to the effects of this assistance on your financial condition and results of ope rations pursuant to the guidance in FRC 501.06.c. Effects of Federal Financia l Assistance Upon Operations. You may contact Staci Shannon at (202) 551-3374 or me at (202) 551-3494 if you have questions regarding comments on the fi nancial statements and related matters. Please contact Michael Seaman at (202) 551-3366 or Suzanne Hayes at (202) 551-3675 with any other questions. Sincerely, /s/ Suzanne Hayes Suzanne Hayes Assistant Director