SEC Comment Letter for NEW CENTURY TRS HOLDINGS INC (CIK 0001036075) — Nov 19, 2004
NEW CENTURY TRS HOLDINGS INC (CIK 0001036075)
Date: Nov. 19, 2004 · CIK: 0001036075 · Accession: 0000000000-04-037365
AI Filing Summary & Sentiment
File numbers found in text: 333-120209
Letter
November 16, 2004 Mail Stop 0409 Brad A. Morrice Vice Chairman, President and Chief Operating Officer New Century Financial Corporation 18400 Von Karman, Suite 1000 Irvine, CA 92612
Re: Registration Statement on Form S-4 Filed November 4, 2004 Registration No. 333-120209
Dear Mr. Morrice:
We have limited our review of your filing to the following comment. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Documents Incorporated By Reference, page 81
1. Please revise this section to incorporate by reference the required periodic reports for the predecessor to New Century Financial.
* * * *
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
Notwithstanding our comments, in the event the company requests acceleration of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that
* should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
* the company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
Please contact Owen Pinkerton, Attorney-Advisor, at (202) 942- 1971 or me at (202) 942-1960 with any other questions.
Sincerely,
Karen J. Garnett
Assistant Director
Show Raw Text
<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> November 16, 2004 Mail Stop 0409 Brad A. Morrice Vice Chairman, President and Chief Operating Officer New Century Financial Corporation 18400 Von Karman, Suite 1000 Irvine, CA 92612 Re: Registration Statement on Form S-4 Filed November 4, 2004 Registration No. 333-120209 Dear Mr. Morrice: We have limited our review of your filing to the following comment. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Documents Incorporated By Reference, page 81 1. Please revise this section to incorporate by reference the required periodic reports for the predecessor to New Century Financial. * * * * As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. Notwithstanding our comments, in the event the company requests acceleration of the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that * should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; * the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and * the company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing. We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date. Please contact Owen Pinkerton, Attorney-Advisor, at (202) 942- 1971 or me at (202) 942-1960 with any other questions. Sincerely, Karen J. Garnett Assistant Director cc: Peter T. Healy, Esq. (via facsimile) O`Melveny & Myers LLP New Century Financial Corporation Page 2 </TEXT> </DOCUMENT>