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SEC Comment Letter for SVC FINANCIAL SERVICES INC (CIK 0001092753) — Feb 2, 2005

SVC FINANCIAL SERVICES INC (CIK 0001092753)
Date: Feb. 2, 2005 · CIK: 0001092753 · Accession: 0000000000-05-005347

AI Filing Summary & Sentiment

File numbers found in text: 000-26969

Date
February 2, 2005
Author
Tamara Tangen
Form
UPLOAD
Company
SVC FINANCIAL SERVICES INC (CIK 0001092753)

Letter

February 2, 2005 Via facsimile to (866) 301-1250 and U.S. Mail Mr. Christopher Haigh President SVC Financial Services, Inc. 235 Montgomery Street, Suite 956 San Francisco, CA 94104

Re: SVC Financial Services, Inc. Item 4.01 Form 8-K filed January 24, 2005 File No. 000-26969

Dear Mr. Haigh:

We have reviewed your filing and have the following comments. 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.

Form 8-K filed on January 24, 2005 1. We note the occurrence of events (A) and (C) described within Regulation S-K Item 304(a)(1)(v). For each of these events, revise to provide the information required by paragraph (a)(1)(iv) of Item 304 or tell us why you do not believe a revision is necessary.

General

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the disclosure in the filing;

* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

* the company may not assert staff comments as a 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 our review of your filing or in response to our comments on your filing.

*******

As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. 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.

Any questions regarding the above should be directed to me at (202) 942-1987, or in my absence, to Robert Benton at (202) 942- 1811.

Sincerely,
Tamara Tangen
Staff Accountant

Show Raw Text
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<TEXT>

Mail Stop 04-06

      February 2, 2005

Via facsimile to (866) 301-1250 and U.S. Mail

Mr. Christopher Haigh
President
SVC Financial Services, Inc.
235 Montgomery Street, Suite 956
San Francisco, CA 94104

Re:   	SVC Financial Services, Inc.
      Item 4.01 Form 8-K filed January 24, 2005
      File No. 000-26969

Dear Mr. Haigh:

      We have reviewed your filing and have the following
comments.
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.

Form 8-K filed on January 24, 2005
1. We note the occurrence of events (A) and (C) described within
Regulation S-K Item 304(a)(1)(v).  For each of these events,
revise
to provide the information required by paragraph (a)(1)(iv) of
Item
304 or tell us why you do not believe a revision is necessary.

General

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a 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 our review of your filing or in
response to our comments on your filing.

      *******

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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.

      Any questions regarding the above should be directed to me
at
(202) 942-1987, or in my absence, to Robert Benton at (202) 942-
1811.

Sincerely,

Tamara Tangen
      Staff Accountant

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SVC Financial Services, Inc.
February 2, 2005
Page 2

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