SEC Company Response from SLM Corp (SLM, SLMBP) (CIK 0001032033) (SLM) — Oct 11, 2005
SLM Corp (SLM, SLMBP) (CIK 0001032033)
Date: Oct. 11, 2005 · CIK: 0001032033 · Accession: 0001104659-05-047952
AI Filing Summary & Sentiment
Referenced dates: October 6, 2005, September 19, 2005
Letter
VIA EDGAR Securities and Exchange Commission SLM Corporation Form 10-K for the Fiscal Year Ended December 31, 2004 Forms 10-Q for the Quarters Ended March 31, 2005 and June 30, 2005 File No. 1-13251
Dear Ms. Sweeney:
On behalf of SLM Corporation (the “Company”), submitted below is the Company’s response to the sole comment (the “Comment”) of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the Commission’s letter dated October 6, 2005 concerning the above referenced filings made pursuant to the Securities Exchange Act of 1934 (the “Exchange Act”).
For your convenience, the text of the Staff’s Comment is presented in italics before our response.
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.
Response:
As Mike Sheehan discussed with you on October 7, we agree not to use the title “core cash” measures in our disclosures in future filings. We will instead use the titles “core earnings,” “core results” or “core measures” as appropriate for the context in which they are used.
We believe that the foregoing is responsive to the Comment. If you need any further information, please do not hesitate to call me at 703.984.6800 or Mike Sheehan at 703.984.5680.
Very truly
yours,
/S/ C.E. ANDREWS
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CORRESP 1 filename1.htm SLM CORPORATION 12061 BLUEMONT WAY RESTON, VIRGINIA 20190 C.E. Andrews Executive Vice President, Finance, Accounting and Risk Management 703-984-6800 October 10, 2005 VIA EDGAR Ms. Joyce Sweeney Branch Chief Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: SLM Corporation Form 10-K for the Fiscal Year Ended December 31, 2004 Forms 10-Q for the Quarters Ended March 31, 2005 and June 30, 2005 File No. 1-13251 Dear Ms. Sweeney: On behalf of SLM Corporation (the “Company”), submitted below is the Company’s response to the sole comment (the “Comment”) of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the Commission’s letter dated October 6, 2005 concerning the above referenced filings made pursuant to the Securities Exchange Act of 1934 (the “Exchange Act”). For your convenience, the text of the Staff’s Comment is presented in italics before our response. 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. Response: As Mike Sheehan discussed with you on October 7, we agree not to use the title “core cash” measures in our disclosures in future filings. We will instead use the titles “core earnings,” “core results” or “core measures” as appropriate for the context in which they are used. We believe that the foregoing is responsive to the Comment. If you need any further information, please do not hesitate to call me at 703.984.6800 or Mike Sheehan at 703.984.5680. Very truly yours, /S/ C.E. ANDREWS C.E. Andrews Attachments cc: SEC Chris Harley SLM Corporation William M. Diefenderfer, Chair, Audit Committee of the Board of Directors Marianne M. Keler, Executive Vice President, Corporate Strategy, Consumer Lending & Administration Robert A. Crawford, Senior Vice President & Controller Robert S. Lavet, Senior Vice President & General Counsel Ted Morris, Vice President, Accounting Policy & Capital Markets Accounting Michael E. Sheehan, Vice President & Deputy General Counsel Peter W. Strang, Vice President & Assistant Controller Gibson, Dunn & Crutcher LLP Ronald O. Mueller 2