SEC Comment Letter for CME GROUP INC. (CME) (CIK 0001156375) (CME) — Oct 3, 2006
CME GROUP INC. (CME) (CIK 0001156375)
Date: Oct. 3, 2006 · CIK: 0001156375 · Accession: 0000000000-06-047753
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-33379
Referenced dates: August 3, 2006
Letter
October 3, 2006 Mail Stop 4561 Mr. Craig S. Donohue Chief Executive Officer and Director Chicago Mercantile Exchange Holdings Inc. 20 South Wacker Drive Chicago, Illinois 60606
Re: Chicago Mercantile Exchange Holdings Inc. Form 10-K for Fiscal Year Ended December 31, 2005 Filed March 6, 2006 File Number: 000-33379
Dear Mr. Donohue:
We have reviewed your response to ou r comment letter dated August 3, 2006 and have the following comment. Where i ndicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappli cable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with supplemental information so we ma y better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our re view 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Craig S. Donohue Chicago Mercantile Exchange Holdings Inc. October 3, 2006 Page 2
Form 10-K, filed March 6, 2006
Consolidated Statements of Income, page 57 1. We note your response to comment 2 from our letter dated August 3, 2006. Please tell us how you considered the guidance in EITF 99-19 to support your presentation of securities lending expense as a reduction of total revenues to arrive at net revenues. We continue to believe that securities lending expense should be presented within your expenses in your income statement rather than as a reduction of revenues in accordance w ith Article 5 of Regulation S-X.
* * * * *
As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and provides any re quested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact John Spitz, Staff Acc ountant at (202) 551-3484, or me at (202) 551-3490, if you have questions re garding these comments.
Sincerely,
Don Walker
Senior Assistant Chief Accountant
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October 3, 2006 Mail Stop 4561 Mr. Craig S. Donohue Chief Executive Officer and Director Chicago Mercantile Exchange Holdings Inc. 20 South Wacker Drive Chicago, Illinois 60606 Re: Chicago Mercantile Exchange Holdings Inc. Form 10-K for Fiscal Year Ended December 31, 2005 Filed March 6, 2006 File Number: 000-33379 Dear Mr. Donohue: We have reviewed your response to ou r comment letter dated August 3, 2006 and have the following comment. Where i ndicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inappli cable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with supplemental information so we ma y better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our re view 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Mr. Craig S. Donohue Chicago Mercantile Exchange Holdings Inc. October 3, 2006 Page 2 Form 10-K, filed March 6, 2006 Consolidated Statements of Income, page 57 1. We note your response to comment 2 from our letter dated August 3, 2006. Please tell us how you considered the guidance in EITF 99-19 to support your presentation of securities lending expense as a reduction of total revenues to arrive at net revenues. We continue to believe that securities lending expense should be presented within your expenses in your income statement rather than as a reduction of revenues in accordance w ith Article 5 of Regulation S-X. * * * * * As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and provides any re quested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment. You may contact John Spitz, Staff Acc ountant at (202) 551-3484, or me at (202) 551-3490, if you have questions re garding these comments. Sincerely, Don Walker Senior Assistant Chief Accountant