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SEC Comment Letter for MONTPELLIER GROUP INC (CIK 0001206120) — Oct 19, 2005

MONTPELLIER GROUP INC (CIK 0001206120)
Date: Oct. 19, 2005 · CIK: 0001206120 · Accession: 0000000000-05-053334

AI Filing Summary & Sentiment

Date
October 19, 2005
Author
Thomas Flinn
Form
UPLOAD
Company
MONTPELLIER GROUP INC (CIK 0001206120)

Letter

Mail Stop 4561 October 19, 2005 Mr. Roland Vetter President Montpellier Group Inc. 15321 Main St. NE. 152 Duvall, WA 98019

RE: Montpellier Group Inc. Form 8-K Filed October 18, 2005 File No. 0-50103

Dear Mr. Vetter:

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 comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. 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.

Form 8-K filed October 18, 2005

1. Please amend your Form 8-K to state whether during the registrant`s two most recent fiscal years and the subsequent interim period through October 14, 2005 there were any disagreements with the former accountant as required by Item 304(a)(1)(iv) of Regulation S- K.

2. When you file the amended Form 8-K please obtain and file an Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8- K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 that they have provided all information investors require for an informed investment 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.

Please provide the information requested above within five business days from the date of this letter. The information should be filed as correspondence on EDGAR.

Any questions regarding the above should be directed to me at (202) 551-3469.

Sincerely,
Thomas Flinn
Staff Accountant
Mr. Roland Vetter
Montpellier Group Inc.
October 19, 2005
Page 1

Show Raw Text
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<TEXT>

Mail Stop 4561
      October 19, 2005

Mr. Roland Vetter
President
Montpellier Group Inc.
15321 Main St. NE. 152
Duvall, WA 98019

	RE:	Montpellier Group Inc.
		Form 8-K
		Filed October 18, 2005
            	File No. 0-50103

Dear Mr. Vetter:

      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 comments are inapplicable or a revision
is
unnecessary.  Please be as detailed as necessary in your
explanation.
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.

Form 8-K filed October 18, 2005

1. Please amend your Form 8-K to state whether during the
registrant`s two most recent fiscal years and the subsequent
interim
period through October 14, 2005 there were any disagreements with
the
former accountant as required by Item 304(a)(1)(iv) of Regulation
S-
K.

2. When you file the amended Form 8-K please obtain and file an
Exhibit 16 letter from the former accountants stating whether the
accountant agrees with the statements made in your revised Form 8-
K.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 that they have provided all information
investors require for an informed investment 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.

	Please provide the information requested above within five
business days from the date of this letter.  The information
should
be filed as correspondence on EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3469.

								Sincerely,

								Thomas Flinn
								Staff Accountant
Mr. Roland Vetter
Montpellier Group Inc.
October 19, 2005
Page 1

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