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) — Aug 2, 2013
MORGAN STANLEY (MS, MS-PA, MS-PE, MS-PF, MS-PI, MS-PK, MS-PL, MS-PO, MS-PP, MS-PQ) (CIK 0000895421)
Date: Aug. 2, 2013 · CIK: 0000895421 · Accession: 0000000000-13-042516
AI Filing Summary & Sentiment
Reasoning
Referenced dates: July 11, 2013
Letter
August 2 , 2013 Via E -Mail Ruth Porat Executive Vice President and Chief Financial Officer Morgan Stanley 1585 Broadway New York, N Y 10036
Re: Morgan Stanley Form 10 -K for Fiscal Year Ended December 31, 2012 Filed February 2 6, 2013 File No. 001 -11758
Dear Ms. Porat:
We have reviewed your response letter dated July 24 , 2013, and have the following comments. In some of our comments, 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 request ed information, or by advising us when you will provide the requested response. Where we have requested changes in future filings, please include a draft of your proposed disclosures that clearly identifies new or revised disclosures. If you do not belie ve our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, includi ng the draft of your proposed disclosures, we may have additional comments.
Form 10 -K for the Year Ended December 31, 2012
Item 9 – Changes in and Disagreements with Accountants on Accounting and Financial Disclosure, page 290
9A – Controls and Proced ures, page 290
1. We note your response to comment one of our letter dated July 11, 2013 . In light of the multiple significant deficiencies involving multiple accounts and processes specifically identified in your responses dated May 20 and July 24, 2013 and the fact that some relate
Ruth Porat Morgan Stanley August 2, 2013 Page 2
to areas of financial reporting where errors were identified as a result of inquiries from your independent auditor, please provide further information to help us understand how you have evaluated the controls related to the Risk Assessment and Monitoring components of COSO to identify whether control deficiencies existed. Specifically, please discuss in the context of each of the significant deficiencies whether and how the company’s monitoring or risk assessment controls detected those deficiencies or otherwise whether each of the identified significant deficiencies are indi cative of additional deficiencies in risk assessment or monitoring controls. To the extent tha t deficiencies were identified , or are identified in the proce ss of responding to our inquiry , in either of these components, please describe them and elaborate on how you have evaluated their severity.
You may contact Yolanda Trotter at (202) 551 -3472 or me at (202) 551 -3494 with any questions .
Sincerely,
/s/ Kevin W. Vaughn
Show Raw Text
August 2 , 2013
Via E -Mail
Ruth Porat
Executive Vice President and Chief Financial Officer
Morgan Stanley
1585 Broadway
New York, N Y 10036
Re: Morgan Stanley
Form 10 -K for Fiscal Year Ended December 31, 2012
Filed February 2 6, 2013
File No. 001 -11758
Dear Ms. Porat:
We have reviewed your response letter dated July 24 , 2013, and have the following
comments. In some of our comments, 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 request ed information, or by advising us when you will provide the requested
response. Where we have requested changes in future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosures. If you do not belie ve our
comments apply to your facts and circumstances or do not believe an amendment is appropriate,
please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, includi ng the draft of your proposed disclosures, we may have
additional comments.
Form 10 -K for the Year Ended December 31, 2012
Item 9 – Changes in and Disagreements with Accountants on Accounting and Financial
Disclosure, page 290
9A – Controls and Proced ures, page 290
1. We note your response to comment one of our letter dated July 11, 2013 . In light of the
multiple significant deficiencies involving multiple accounts and processes specifically
identified in your responses dated May 20 and July 24, 2013 and the fact that some relate
Ruth Porat
Morgan Stanley
August 2, 2013
Page 2
to areas of financial reporting where errors were identified as a result of inquiries from
your independent auditor, please provide further information to help us understand how
you have evaluated the controls related to the Risk Assessment and Monitoring
components of COSO to identify whether control deficiencies existed. Specifically,
please discuss in the context of each of the significant deficiencies whether and how the
company’s monitoring or risk assessment controls detected those deficiencies or
otherwise whether each of the identified significant deficiencies are indi cative of
additional deficiencies in risk assessment or monitoring controls. To the extent tha t
deficiencies were identified , or are identified in the proce ss of responding to our inquiry ,
in either of these components, please describe them and elaborate on how you have
evaluated their severity.
You may contact Yolanda Trotter at (202) 551 -3472 or me at (202) 551 -3494 with any
questions .
Sincerely,
/s/ Kevin W. Vaughn
Kevin W. Vaughn
Accounting Branch Chief