SEC Company Response from PENNFED FINANCIAL SERVICES INC (CIK 0000920945) — Sep 21, 2005
PENNFED FINANCIAL SERVICES INC (CIK 0000920945)
Date: Sept. 21, 2005 · CIK: 0000920945 · Accession: 0000914317-05-002920
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File numbers found in text: 000-24040
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September 21, 2005
United States Securities and Exchange Commission
100 F Street, N.W.
Washington, D.C. 20549
Attn: Lisa Haynes
Re: PennFed Financial Services, Inc.
Item 4.02 Form 8-K
Filed September 7, 2005
File No. 000-24040
Dear Ms. Haynes,
As discussed, per the September 12, 2005 letter from Amit Pande, we are
preparing an amendment to our previously issued Form 8-K addressing comments
from the SEC. Responses and requested information are as follows:
Response to Item 1. a.
In researching your comment requesting the date on which our new independent
accountants informed us about the Statement of Cash Flow classification errors
described in the second paragraph of the Form 8-K, we determined that it was in
fact not the September 30, 2004 Form 10-Q which reflected the classification
error but the December 31, 2004 Form 10-Q. We are, however, unable to provide a
specific date as to when KPMG informed us of the accounting under SFAS 102
because, at the time of the filing of the December 31, 2004 Form 10-Q, the
Company deemed the change to be a reclassification - not an error requiring
restatement.
Response to Item 1. b.
With respect to how we determined that we were not required to file a Form 8-K
Item 4.02 - as indicated above, at the time of the filing of the December 31,
2004 Form 10-Q, the Company deemed the change to be a reclassification - not an
error requiring restatement; accordingly, no Form 8-K to report the change was
then required.
Response to Item 1. c.
With respect to the sequence of events, we will expand slightly the language in
the previously filed Form 8-K to provide the reader a better explanation of
events that occurred.
Changes to the previously filed Form 8-K
Within the second paragraph, references to the quarter ended September 30, 2004
will be changed to the quarter ended December 31, 2004.
At the end of the second paragraph, the following would be added:
At the time of the filing of the December 31, 2004 Form 10-Q, the Company deemed
the change to be a reclassification - not an error requiring restatement;
accordingly, no Form 8-K to report the change was then required.
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On August 31, 2005, in connection with the preparation of the June 30,
2005 Form 10-K, management revisited the reclassification item in discussions
with D&T and KPMG LLP. Following these discussions, management concluded that
restatement was appropriate. Management informed the Audit Committee of these
discussions and its conclusion at the meeting of the Audit Committee on
September 1, 2005.
At the end of the third paragraph, the following sentence will be deleted:
Prior to the Audit Committee's making its decision to restate the 2004 and
2003 consolidated statements of cash flows, the Company's management discussed
this matter with both KPMG LLP and Deloitte & Touche LLP.
Response to Item 2.
We advise you that the certifying officers have considered the effect of the
errors on previous disclosures regarding internal controls and the effectiveness
of disclosure controls and procedures as of the end of the period covered by our
2004 Form 10-K and Forms 10-Q for the periods ended December 31, 2004 and March
31, 2005. The certifying officers reiterate those certifications. The statement
of cash flow classification error had no effect on our evaluation of disclosure
controls and procedures as of June 30, 2005 because the error was corrected
prior to that date.
Please do not hesitate to contact me if you need any further information.
Sincerely,
/s/ Claire M. Chadwick
Claire M. Chadwick
Executive Vice President and
Chief Financial Officer
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