Securities Lawyer's Deskbook
                         published by The University of Cincinnati College of Law
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Standard Instructions for Filing Forms under
the Securities Act of 1933, Securities Exchange Act of 1934, and Energy Policy and Conservation Act of 1975

Regulation S-K





Item 601T of Regulation S-K


Any issuer that may rely upon the alternative disclosure requirement of Item 304T shall comply with Item 601(b)(16) in the following manner:

  1. If Arthur Andersen LLP (or a foreign affiliate of Arthur Andersen LLP) has already provided the issuer with a letter addressed to the Commission stating whether it agrees or disagrees with the statements made by the issuer in response to Item 304(c) [Editor's Note: It appears this should be Item 304(b)], the issuer must comply with Item 601(b)(16).

  2. If Arthur Andersen LLP (or a foreign affiliate of Arthur Andersen LLP) has not provided the issuer with this letter and the issuer cannot obtain it after reasonable efforts, the issuer need not comply with Item 601(b)(16).

  3. This temporary section will expire on December 31, 2002.


Regulatory History


67 FR 13518, 13536, Mar. 22, 2002



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