SEC Comment Letter for HEALTHCARE BUSINESS SERVICES GROUPS, INC. (CIK 0001192069) — Dec 16, 2004
HEALTHCARE BUSINESS SERVICES GROUPS, INC. (CIK 0001192069)
Date: Dec. 16, 2004 · CIK: 0001192069 · Accession: 0000000000-04-040560
AI Filing Summary & Sentiment
Letter
December 3, 2004 Mail Stop 0409 Via U.S. Mail and Fax (702) 314-2811 Ms. Chandana Basu Chief Executive Officer Winfield Financial Group, Inc. 1126 West Foothill Blvd., Suite 105 Upland, CA 91786
Re: Winfield Financial Group, Form 8-K filed November 24, 2004
Dear Ms. Basu:
We have reviewed your filing and have the following comments. In our comments, we 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 on any other aspect of our review. Feel free to call me at the telephone number listed at the end of this letter.
Disagreements:
1. Refer to the third and fourth paragraphs of the Item 4.01 of the Form 8-K where you identify an accounting disagreement. For the disagreement, please tell us supplementally:
* The Company`s position and the former accountant`s position at the time of the disagreement * How the disagreement was resolved? * How the disagreed amounts were determined?
2. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 comment, 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.
Please provide the supplemental information requested above within business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR. You may reach me at (202) 942-2913 with any questions.
Sincerely,
Andrew Mew
Staff Accountant
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>winfieldltr.txt
<DESCRIPTION>ITEM 4 FORM 8-K DTD 11/24/04 MEW
<TEXT>
December 3, 2004
Mail Stop 0409
Via U.S. Mail and Fax (702) 314-2811
Ms. Chandana Basu
Chief Executive Officer
Winfield Financial Group, Inc.
1126 West Foothill Blvd.,
Suite 105
Upland, CA 91786
Re: Winfield Financial Group, Form 8-K filed November 24, 2004
Dear Ms. Basu:
We have reviewed your filing and have the following comments. In
our
comments, we 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 on any other
aspect
of our review. Feel free to call me at the telephone number
listed
at the end of this letter.
Disagreements:
1. Refer to the third and fourth paragraphs of the Item 4.01 of
the
Form 8-K where you identify an accounting disagreement. For the
disagreement, please tell us supplementally:
* The Company`s position and the former accountant`s position at
the
time of the disagreement
* How the disagreement was resolved?
* How the disagreed amounts were determined?
2.
We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require. 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 comment, 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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.
Please provide the supplemental information requested above within
10
business days from the date of this letter. The supplemental
information should be filed as correspondence on EDGAR. You may
reach me at (202) 942-2913 with any questions.
Sincerely,
Andrew Mew
Staff Accountant
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Winfield Financial Group, Inc.
December 3, 2004
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