SEC Company Response from ATM FINANCIAL CORP (CIK 0001221554) — Dec 5, 2005
ATM FINANCIAL CORP (CIK 0001221554)
Date: Dec. 5, 2005 · CIK: 0001221554 · Accession: 0001303681-05-000040
AI Filing Summary & Sentiment
File numbers found in text: 333-103647
Letter
December 4, 2005 VIA EDGAR Yolanda Crittendon Staff Accountant Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549
Re: ATM FINANCIAL CORP. FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004 FORM 10-QSB FOR THE QUARTERS ENDED MARCH 31, 2005, JUNE 30, 2005, AND SEPTEMBER 30, 2005 FILE NO. 333-103647
Dear Ms. Crittendon:
In connection with the above-captioned filings our responses to the Staff's comments are set forth below in the following paragraphs numbered to correspond to the comments in the Staff's letter.
FORM 10-QSB FOR THE PERIOD ENDING MARCH 31, 2005
ITEM 1 - FINANCIAL STATEMENTS
STATEMENT OF OPERATIONS
1. In response to the Staff's comment, we advise that the debt settlement was the result of dispute over fees charged by our respective legal counsel and accountants that ultimately culminated in negotiated settlements. Statements of account were recorded as operational expenses as billed. Disputed amounts were not paid. As a result of the negotiated settlements, disputed amounts were written off by the respective service providers. We therefore recorded a debt settlement gain in our financial statements with no change in cash outflow.
FORM 10-QSB FOR THE QUARTERS ENDED MARCH 31, 2005, JUNE 30, 2005, AND SEPTEMBER 30, 2005
ITEM 3 - CONTROLS AND PROCEDURES
2. In response to the Staff's comment, we confirm that we will revise our disclosure in future filings.
3. In response to the Staff's comment, we confirm that our officers have concluded that our disclosure controls and procedures are effective as at the end of the period covered by the quarterly reports. We further confirm that we will revise our disclosure in future filings to clearly set out the conclusions reached by our officers as to the effectiveness of our disclosure controls and procedures.
Should the Staff need additional information or have questions concerning our response, please do not hesitate to contact us.
Yours very truly,
/s/ Arthur Davis Arthur Davis President & CEO
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
ATM FINANCIAL CORP. 2533 North Carson Street
Carson City, Nevada 89706
tel: (775) 841-7018
fax: (775) 883-2384
December 4, 2005
VIA EDGAR
Yolanda Crittendon
Staff Accountant
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: ATM FINANCIAL CORP.
FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004
FORM 10-QSB FOR THE QUARTERS ENDED MARCH 31, 2005, JUNE 30, 2005,
AND SEPTEMBER 30, 2005
FILE NO. 333-103647
Dear Ms. Crittendon:
In connection with the above-captioned filings our responses to the Staff's
comments are set forth below in the following paragraphs numbered to correspond
to the comments in the Staff's letter.
FORM 10-QSB FOR THE PERIOD ENDING MARCH 31, 2005
ITEM 1 - FINANCIAL STATEMENTS
STATEMENT OF OPERATIONS
1. In response to the Staff's comment, we advise that the debt settlement
was the result of dispute over fees charged by our respective legal counsel and
accountants that ultimately culminated in negotiated settlements. Statements of
account were recorded as operational expenses as billed. Disputed amounts were
not paid. As a result of the negotiated settlements, disputed amounts were
written off by the respective service providers. We therefore recorded a debt
settlement gain in our financial statements with no change in cash outflow.
FORM 10-QSB FOR THE QUARTERS ENDED MARCH 31, 2005, JUNE 30, 2005,
AND SEPTEMBER 30, 2005
ITEM 3 - CONTROLS AND PROCEDURES
2. In response to the Staff's comment, we confirm that we will revise our
disclosure in future filings.
3. In response to the Staff's comment, we confirm that our officers have
concluded that our disclosure controls and procedures are effective as at the
end of the period covered by the quarterly reports. We further confirm that we
will revise our disclosure in future filings to clearly set out the conclusions
reached by our officers as to the effectiveness of our disclosure controls and
procedures.
Should the Staff need additional information or have questions concerning our
response, please do not hesitate to contact us.
Yours very truly,
/s/ Arthur Davis
Arthur Davis
President & CEO
</TEXT>
</DOCUMENT>