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
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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
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