SEC Comment Letter for GRUPO RADIO CENTRO SA DE CV (CIK 0000906526) — Sep 12, 2005
GRUPO RADIO CENTRO SA DE CV (CIK 0000906526)
Date: Sept. 12, 2005 · CIK: 0000906526 · Accession: 0000000000-05-047081
AI Filing Summary & Sentiment
Referenced dates: July 19, 2005, July 27, 2005
Letter
Via U.S. Mail and Fax 525-728-4875 Pedro Beltran Nasr Chief Financial Officer GRUPO RADIO CENTRO, S.A. DE C.V. Constituyentes 1154 - 7 Piso Col Lomas Altas, C.P. 11950 Mexico, D.F., Mexico File No. 1-12090
Re: GRUPO RADIO CENTRO, S.A. DE C.V. Form 20-F for the year ended December 31, 2004 Filed June 29, 2005
Dear Mr. Beltran
We have reviewed your supplemental response letter dated July 27, 2005 as well as your filing and have the following comments. As noted in our comment letter dated July 19, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 20-F for the year ended December 31, 2004
1. We note your response to comment 2. Since on March 31, 2005 you obtained a waiver of non-compliance with the covenants of the loan agreement only through December 31, 2005, it appears to us that in accordance with SFAS 78 and EITF 86-30, you should classify the full amount of the outstanding loan balance as a current liability as of December 31, 2004. Revise or advise.
2. We note your response to our comments 3 and 4. We note that your General Director reviews GRC`s financial information on a consolidated basis for purposes of making operating decisions and assessing financial performance. Addressing paragraph 12 of SFAS 131, tell us how you determined who is your CODM. In addition, provide us with the financial information that your chief operating decision maker uses to allocate resources and assess performance.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. You may contact Al Rodriguez, Staff Accountant, at (202) 551-3370 or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions. Please file your response letter on EDGAR.
Sincerely,
/s/ Carlos Pacho
for Larry Spirgel
Assistant Director
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Mail Stop 3561 August 12, 2005
Via U.S. Mail and Fax 525-728-4875
Pedro Beltran Nasr
Chief Financial Officer
GRUPO RADIO CENTRO, S.A. DE C.V.
Constituyentes 1154 - 7 Piso
Col Lomas Altas, C.P. 11950
Mexico, D.F., Mexico
Re: GRUPO RADIO CENTRO, S.A. DE C.V.
Form 20-F for the year ended December 31, 2004
Filed June 29, 2005
File No. 1-12090
Dear Mr. Beltran
We have reviewed your supplemental response letter dated July 27,
2005 as well as your filing and have the following comments. As
noted in our comment letter dated July 19, 2005, we have limited
our
review to your financial statements and related disclosures and do
not intend to expand our review to other portions of your
documents.
Form 20-F for the year ended December 31, 2004
1. We note your response to comment 2. Since on March 31, 2005
you
obtained a waiver of non-compliance with the covenants of the loan
agreement only through December 31, 2005, it appears to us that in
accordance with SFAS 78 and EITF 86-30, you should classify the
full
amount of the outstanding loan balance as a current liability as
of
December 31, 2004. Revise or advise.
2. We note your response to our comments 3 and 4. We note that
your
General Director reviews GRC`s financial information on a
consolidated basis for purposes of making operating decisions and
assessing financial performance. Addressing paragraph 12 of SFAS
131, tell us how you determined who is your CODM. In addition,
provide us with the financial information that your chief
operating
decision maker uses to allocate resources and assess performance.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. You may contact
Al
Rodriguez, Staff Accountant, at (202) 551-3370 or Carlos Pacho,
Senior Assistant Chief Accountant, at (202) 551-3835 if you have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3810 with any other
questions. Please file your response letter on EDGAR.
Sincerely,
/s/ Carlos Pacho
for Larry Spirgel
Assistant Director
??
??
??
??
Pedro Beltran Nasr
GRUPO RADIO CENTRO, S.A. DE C.V.
September 12, 2005
Page 1 of 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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