SEC Comment Letter for SLM Corp (SLM, SLMBP) (CIK 0001032033) (SLM) — Oct 6, 2005
SLM Corp (SLM, SLMBP) (CIK 0001032033)
Date: Oct. 6, 2005 · CIK: 0001032033 · Accession: 0000000000-05-051482
AI Filing Summary & Sentiment
File numbers found in text: 001-13251
Referenced dates: October 3, 2005, September 19, 2005
Letter
Mail Stop 4561 October 6, 2005 Mr. C.E. Andrews Executive Vice President, Finance SLM Corporation 12061 Bluemont Way Reston, Virginia 20190
Re: SLM Corporation Form 10-K for the fiscal year ended December 31, 2004 Forms 10-Q for quarterly periods ended March 31, 2005 and June 30, 2005 File No. 001-13251
Dear Mr. Andrews:
We have reviewed your response letter dated October 3, 2005 and have considered the supplemental information provided by the company. We have the following additional comment.
Form 10-K for the fiscal year ended December 31, 2004 Alternative Performance Measures, pages 61-64
1. We note your supplemental response to comment 1 of our letter dated September 19, 2005. In future filings, please do not use the title "core cash" measures in your disclosures. Reference to cash performance measures may be confusing to investors since your non- GAAP measure does not appear to represent cash flows or a liquidity measure.
Please respond to this comment within ten business days or tell us when you will respond. You may contact Chris Harley at (202) 551- 3695 or me at (202) 551-3449 if you have questions regarding this comment on the financial statements and related matters.
Sincerely,
Joyce Sweeney
Branch Chief
Show Raw Text
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<TEXT>
Mail Stop 4561
October 6, 2005
Mr. C.E. Andrews
Executive Vice President, Finance
SLM Corporation
12061 Bluemont Way
Reston, Virginia 20190
Re: SLM Corporation
Form 10-K for the fiscal year ended
December 31, 2004
Forms 10-Q for quarterly periods ended
March 31, 2005 and June 30, 2005
File No. 001-13251
Dear Mr. Andrews:
We have reviewed your response letter dated October 3, 2005
and
have considered the supplemental information provided by the
company.
We have the following additional comment.
Form 10-K for the fiscal year ended December 31, 2004
Alternative Performance Measures, pages 61-64
1. We note your supplemental response to comment 1 of our letter
dated September 19, 2005. In future filings, please do not use
the
title "core cash" measures in your disclosures. Reference to cash
performance measures may be confusing to investors since your non-
GAAP measure does not appear to represent cash flows or a
liquidity
measure.
Please respond to this comment within ten business days or
tell
us when you will respond. You may contact Chris Harley at (202)
551-
3695 or me at (202) 551-3449 if you have questions regarding this
comment on the financial statements and related matters.
Sincerely,
Joyce Sweeney
Branch Chief
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</TEXT>
</DOCUMENT>