SEC Comment Letter for Refco Inc. (CIK 0001321746) — Oct 13, 2005
Refco Inc. (CIK 0001321746)
Date: Oct. 13, 2005 · CIK: 0001321746 · Accession: 0000000000-05-052492
AI Filing Summary & Sentiment
File numbers found in text: 001-32604
Letter
Mail Stop 4561 October 13, 2005 Gerald M. Sherer Chief Financial Officer Refco Inc. One World Financial Center 200 Liberty Street, Tower A New York, New York 10281
RE: Refco Inc. Item 4.02 Form 8-K Filed October 11, 2005 File No. 001-32604
Dear Mr. Sherer,
We have reviewed your filing and have the following comment. In our comment, we have asked you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. Please tell us whether you intend to file restated financial statements. If so, tell us when you will do so.
As appropriate, please respond to this comment within five business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment.
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 and 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 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 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 comment on your filing.
You may contact Michael Volley, Staff Accountant, at (202) 551- 3437 or me at (202) 551- 3494 if you have questions regarding our comment.
Sincerely,
Kevin Vaughn
Branch Chief
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 4561 October 13, 2005 Gerald M. Sherer Chief Financial Officer Refco Inc. One World Financial Center 200 Liberty Street, Tower A New York, New York 10281 RE: Refco Inc. Item 4.02 Form 8-K Filed October 11, 2005 File No. 001-32604 Dear Mr. Sherer, We have reviewed your filing and have the following comment. In our comment, we have asked you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may 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 comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. Please tell us whether you intend to file restated financial statements. If so, tell us when you will do so. As appropriate, please respond to this comment within five business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment. 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 and 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 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 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 comment on your filing. You may contact Michael Volley, Staff Accountant, at (202) 551- 3437 or me at (202) 551- 3494 if you have questions regarding our comment. Sincerely, Kevin Vaughn Branch Chief ?? ?? Gerald M. Sherer Refco Inc. October 13, 2005 Page 2 </TEXT> </DOCUMENT>