SEC Comment Letter for UNITED WISCONSIN GRAIN PRODUCERS LLC (CIK 0001169852) — Oct 18, 2005
UNITED WISCONSIN GRAIN PRODUCERS LLC (CIK 0001169852)
Date: Oct. 18, 2005 · CIK: 0001169852 · Accession: 0000000000-05-053129
AI Filing Summary & Sentiment
Referenced dates: October 10, 2005, September 29, 2005
Letter
October 18, 2005 Via U.S. mail and facsimile J.F. Robertson Chief Executive Officer United Wisconsin Grain Producers, LLC W1231 Tessman Road Cambria, Wisconsin 53923
RE: Form 10-KSB for the fiscal year ended December 31, 2004 Forms 10-QSB for the fiscal quarters ended March 31, 2005 and June 30, 2005 File No. 0-50733
Dear Mr. Robertson:
We have reviewed your response letter dated October 10, 2005 and have the following additional 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 information so we may better understand your disclosure. After reviewing this information, we raise additional comments. 1. 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 their filings; * 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. Form 10-QSB for the Fiscal Quarter Ended June 30, 2004
1. Summary of Significant Accounting Policies, page 9
Derivative Instruments, page 10 2. We note your response to comment 7 in our letter dated September 29, 2005. Your response did not address how you intend to reflect the restricted cash related to your derivative instrument positions to be presented as "margin deposits" in future filings. Please tell us where you intend to present the changes in this balance on your statements of cash flows in future filings. Please also tell us your basis in GAAP which supports your conclusion regarding the presentation. Refer to paragraph 7 of SFAS 95 for guidance.
* * * *
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Meagan Caldwell, Staff Accountant, at (202) 551- or, in her absence, Tracey Houser at (202) 551-3736.
Sincerely,
Nili Shah
Accounting Branch Chief
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 7010
October 18, 2005
Via U.S. mail and facsimile
J.F. Robertson
Chief Executive Officer
United Wisconsin Grain Producers, LLC
W1231 Tessman Road
Cambria, Wisconsin 53923
RE: Form 10-KSB for the fiscal year ended December 31, 2004
Forms 10-QSB for the fiscal quarters ended March 31, 2005 and June
30, 2005
File No. 0-50733
Dear Mr. Robertson:
We have reviewed your response letter dated October 10,
2005 and have the following additional 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 information so we may better understand your disclosure.
After reviewing this information, we raise additional comments.
1. 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 their filings;
* 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.
Form 10-QSB for the Fiscal Quarter Ended June 30, 2004
1. Summary of Significant Accounting Policies, page 9
Derivative Instruments, page 10
2. We note your response to comment 7 in our letter dated
September
29, 2005. Your response did not address how you intend to reflect
the restricted cash related to your derivative instrument
positions
to be presented as "margin deposits" in future filings. Please
tell
us where you intend to present the changes in this balance on your
statements of cash flows in future filings. Please also tell us
your
basis in GAAP which supports your conclusion regarding the
presentation. Refer to paragraph 7 of SFAS 95 for guidance.
* * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information. Detailed
response
letters greatly facilitate our review. Please file your response
letter on EDGAR. Please understand that we may have additional
comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please
direct them to Meagan Caldwell, Staff Accountant, at (202) 551-
3754
or, in her absence, Tracey Houser at (202) 551-3736.
Sincerely,
Nili Shah
Accounting Branch Chief
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Mr. J.F. Robertson
United Wisconsin Grain Producers, LLC
October 18, 2005
Page 1 of 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
</TEXT>
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